Integrated Advisors Network LLC

Item 1 – Cover Sheet Abundantia Capital Corp Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 990 Stevens Lane McGregor, TX 76657 (254) 242-4571 March 31, 2026 This brochure provides information about the qualifications and business practices of Abundantia Capital Corp. If you have any questions about the contents of this brochure, please contact us at (254) 242-4571, or by email at hugh@abufinance.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training.  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) In Arrears Clarification Within this section, Integrated clarified the definition of “in arrears”. Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) 2  Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................4 Item 4 – Advisory Business ........................................................................................................................................5 Item 5 – Fees and Compensation .............................................................................................................................. 17 Item 6 – Performance Fees ....................................................................................................................................... 20 Item 7 – Types of Clients ......................................................................................................................................... 20 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................................. 21 Item 9 – Disciplinaary Information .......................................................................................................................... 21 Item 10 – Other Financial Idustry Activites and Affiliations ................................................................................... 35 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................... 36 Item 12 – Brokerage Practices .................................................................................................................................. 36 Item 13 – Review of Accounts ................................................................................................................................. 43 Item 14 – Client Referrals and Other Compensation ............................................................................................... 45 Item 15 - Custody ..................................................................................................................................................... 46 Item 16 – Investment Discretion .............................................................................................................................. 47 Item 17 – Voting Client Securities ........................................................................................................................... 48 Item 18 – Financial Information ............................................................................................................................... 48 4  Item 4 – Advisory Business Description of Firm Abundantia Capital Corp is a dba of the registered entity Integrated Advisors Network LLC, collectively hereinafter “the Advisor” or “Abundantia”. Integrated Advisors Network, LLC (“Integrated” or “the Firm”) was founded in 2015 and is a SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. Abundantia is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Hugh Stout is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a 5  percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is 7  compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should 9  consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third party portfolio manager (the “Third Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Advisor Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial 10  practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Abundantia through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Abundantia may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. There is an inherent conflict of interest for Abundantia whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. 13  Abundantia or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of Abundantia. Wealth Coaching, Second Opinions & Financial Analysis Fees Abundantia may provide coaching services that typically do not include investment advisory or management services, financial planning services, nor the review or monitoring of a client’s investment portfolio. The Adviser may recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Adviser. If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. It remains the client’s responsibility to promptly notify the Adviser if there is ever any change in his/her/its situation for the purpose of reviewing/evaluating/revising the Adviser’s previous recommendations and/or services. Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Educational Seminars & Workshop Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. 14  Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, 15  and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. 16  The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Abundantia’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management The Advisor bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. The investment management fees are negotiable at the sole discretion of the Advisor and fees for comparable 17  services may be available from other sources. The Advisor’s Fee can range from .50% through 2.00%, depending upon the passive or active nature of the portfolio. Financial Planning Fees Financial Planning for clients without $300,000+ under management and for complex situations is provided under a fixed fee arrangement agreed upon at the first meeting and based on an hourly rate ranging between, $125 - $250. Fifty percent of the fee is payable in advance before the financial planning process is started. The remaining fifty percent is payable at the end of the engagement. Wealth Coaching, Second Opinions & Financial Analysis Fees Abundantia provides a range of education, coaching and analysis services including "second opinions" on existing investment portfolios. These services are provided based on an hourly rate ranging between $125-$250. An estimate of project cost is made before the project is started. Fifty percent of the fee is payable in advance, and the balance is payable at the end of the engagement. Fee Billing Investment management fees are billed monthly, in arrears (at the end of the month) based on the total market value of the account as shown on the Firm’s provided portfolio statement on the last business day of the month. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The clients of Abundantia will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Adviser’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Abundantia’s fees are the lowest available for similar services. 18  Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. 19  The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients Description The Advisor provides services to institutions, individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates or charitable organizations and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than are disclosed herein. Account Minimums To open and maintain a portfolio management account, the Advisor generally requires that the client represents and warrants that the value of their account initially is at least $50,000. At the Advisor’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. 20  Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Advisor Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: 21  Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based 22  on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) 23  Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. 24  Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. 25  Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various 26  management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in 27  stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP 28  interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff 29  were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have 30  two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals 31  within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. 32  - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could 33  lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced settled charges against Integrated for violations of the Marketing Rule under the Advisers Act. Integrated was censured, ordered to cease and desist from further violations, and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Advisor Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Advisor Representatives, use their name or CRD number in the search function. 34  Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IAR of Abundantia. Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Advisor receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. 35  Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Abundantia and its associated persons do not have any other financial industry activities or affiliations. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, 36  each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. 37  Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment programs, and electronic communication delivery capabilities, 38  • • • • • financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • 39  Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, 40  rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) 41  Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) 42  Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. 43  Clients do not receive regular additional reviews beyond the services contracted in the advisory Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. 44  Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. 45  Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client-directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 46  6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the 47  investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. 48  It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 49 

Item 1 – Cover Sheet All Source Investment Management Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) CityPlace I 185 Asylum Street, Suite 106 Hartford, CT 06103 (860) 904-5219 www.allsourceinvest.com justin.bernier@allsourceinvest.com patrick.kennedy@allsourceinvest.com March 31, 2026 us at: (860) 904-5219 or by email at: justin.bernier@allsourceinvest.com This brochure provides information about the qualifications and business practices of All Source Investment Management (“All Source” or “Advisor”). If you have any questions about the contents of this brochure, please contact or patrick.kennedy@allsourceinvest.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network at compliance@integratedadvisorsnetwork.com or call 855-729-4222. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Additionally, All Source updated its fee schedule chart to include a “standard fee” column. Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) 2  Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................4 Item 4 – Advisory Business ........................................................................................................................................5 Item 5 – Fees and Compensation .............................................................................................................................. 17 Item 6 – Performance Fees ....................................................................................................................................... 20 Item 7 – Types of Clients ......................................................................................................................................... 20 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................................. 21 Item 9 – Disciplinary Action .................................................................................................................................... 34 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................ 34 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................... 37 Item 12 – Brokerage Practices .................................................................................................................................. 38 Item 13 – Review of Accounts ................................................................................................................................. 43 Item 14 – Client Referrals and Other Compensation ............................................................................................... 45 Item 15 - Custody ..................................................................................................................................................... 46 Item 16 – Investment Discretion .............................................................................................................................. 47 Item 17 – Voting of Client Securities ....................................................................................................................... 48 Item 18 – Financial Information ............................................................................................................................... 49 4  Item 4 – Advisory Business Description of Firm All Source Investment Management is a dba of the registered entity Integrated Advisors Network LLC, collectively hereinafter (the “Adviser” “Associate” or “All Source”). Integrated Advisors Network (“Integrated” or “the Firm”) was founded in 2015 and is an SEC-registered investment advisor. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. All Source is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Justin Bernier, Patrick Kennedy and Adam Perlaky are Investment Adviser Representatives (“IARs”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, 5  and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is 7  compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should 9  consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third party portfolio manager (the “Third Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial 10  practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning All Source through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. All Source may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. 13  There is an inherent conflict of interest for All Source whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. All Source or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of All Source. Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Educational Seminars & Workshop Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third 14  party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. 15  Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. 16  Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of All Source’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management The Advisor bases its range of fees as a percentage of assets under management. Although the Investment Management Agreement is an ongoing agreement and constant adjustments are required, the client’s length of service is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance; therefore, at termination, any unearned fees as determined on a pro-rata basis for the portion of the month completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Advisor, and fees for comparable services may be available from other sources. 17  Assets Under Management Standard Annual Fee Maximum Annual Fee $1,000,000 – $2,000,000 1.50% 1.00% $2,000,001 – $5,000,000 1.50% 0.90% $5,000,001 – $10,000,000 1.30% 0.85% $10,000,001 – $25,000,000 1.20% 0.70% Over $25,000,000 Negotiable Negotiable Financial Planning Services The Advisor’s fees for planning services are strictly for planning services. Therefore, clients will pay fees and/or commissions for additional services obtained, such as asset management, or products purchased, such as securities. Fees are negotiable. Client fees will be dependent on several factors, including time spent with All Source, the number of meetings, the complexity of client situation, amount of research, services requested, and resources. Consulting Services All Source will bill clients Consulting Services at a pre-determined fee based upon a percentage of the assets. The exact fee is negotiated in advance of services rendered and is disclosed in the executed written agreement that we sign with the client. Fees will be billed monthly in advance. In special circumstances, other fee-paying arrangements are negotiated. Fee Billing Investment management fees will be billed monthly in advance. For advance fee billing accounts, we invoice you before the monthly billing period has begun, based on the asset value of your account on the last day of the previous month. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the month’s end, regardless of the portfolio’s market performance during the preceding month. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the month in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The clients of All Source will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. 18  Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. All Source’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that All Source fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) 19  Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients Description The Advisor provides services to institutions, high net worth individuals, trusts, foundations, estates or charitable organizations, and corporations or other business entities directly. All Source Investment Management works primarily with accredited investors/qualified purchasers. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. 20  Account Minimums The Advisor does not require an account minimum for clients. However, at its sole discretion, the Advisor may charge a lesser annual advisory fee based upon various factors, including, for example, anticipated future earning capacity, anticipated future assets, historical relationship, client investment experience, related accounts, account composition, negotiations with client, accounts referred to Advisor by another professional, etc. Other advisory groups of Integrated may or may not have any minimum size account. Clients will be required to sign investment advisory agreements (and/or other contractual arrangements) that, among other things, set forth the nature and scope of our investment advisory and management authority, specific services, and the investment objectives, guidelines, and restrictions applicable to the management of client accounts. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Advisor Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. 21  Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. 22  While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. 23  Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. 24  Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. 25  Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each 26  underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, 27  when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with 28  significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of 29  risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. 30  Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price 31  before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. 32  The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for 33  all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Action Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced settled charges against Integrated for violations of the Marketing Rule under the Advisers Act. Integrated was censured, ordered to cease and desist from further violations, and paid a 34  civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Advisor Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Advisor Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of All Source. Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are 35  licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Advisor receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. Justin Bernier, Founding Partner of AllSource Investment Management, serves as Chief Executive of the National Security Emerging Markets Index ETF (“NSI ETF”). Mr. Bernier maintains a minority ownership interest in National Security Index, LLC (“NSI, LLC”), the sponsor and owner of the NSI ETF, and receives pro-rata distributions from the profits generated by the NSI ETF. Certain other Associated Persons of AllSource also hold ownership interests in NSI, LLC. These financial arrangements create a conflict of interest because Mr. Bernier and AllSource have an economic incentive to recommend the NSI ETF to clients. In addition to any advisory fees charged for portfolio management services, Mr. Bernier benefits financially from client investments in the NSI ETF through his ownership interest, resulting in a dual source of compensation. This conflict is fully disclosed to ensure transparency and informed decision-making by clients. To mitigate this conflict, Integrated employs an independent due diligence process to ensure that all investment recommendations—including those involving the NSI ETF—are made in clients’ best interest. This process includes objective evaluation of investment options, consideration of client-specific needs and goals, and documentation of the rationale for each recommendation. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of 36  the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. 37  Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody 38  Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. 39  Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, 40  as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. 41  Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or 42  services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. 43  Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the advisory Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare 44  their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. 45  Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's 46  conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” 47  as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting of Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. 48  While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 49 

Item 1 – Cover Sheet Andersen Capital Management Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 10 Proctor St. Manchester-by-the-Sea, MA 01944 (617) 678-2002 www.andersencapitalmanagement.com March 31, 2026 This brochure provides information about the qualifications and business practices of Andersen Capital Management, LLC. If you have any questions about the contents of this brochure, please contact us at: (617) 678- 2002, or by email at: pandersen@andersencm.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729- 4222. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Adviser is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................4 Item 4 – Advisory Business ........................................................................................................................................5 Item 5 – Fees and Compensation .............................................................................................................................. 16 Item 6 – Performance Fees ....................................................................................................................................... 19 Item 7 – Types of Clients ......................................................................................................................................... 19 Item 8 – Methods of Analysis, Investment Strategies & Risk of Loss ..................................................................... 20 Item 9 – Disciplinary Information ............................................................................................................................ 34 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................ 34 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................... 36 Item 12 – Brokerage Practices .................................................................................................................................. 38 Item 13 – Review of Accounts ................................................................................................................................. 43 Item 14 – Client Referrals and Other Compensation ............................................................................................... 44 Item 15 – Custody .................................................................................................................................................... 45 Item 16 – Investment Discretion .............................................................................................................................. 47 Item 17 – Voting Client Securities ........................................................................................................................... 48 Item 18 – Financial Information ............................................................................................................................... 49 4  Item 4 – Advisory Business Description of Firm Andersen Capital Management, LLC (“the Advisor”, “Associate” or “Andersen Capital Management” or “Andersen”) is a dba of the registered entity Integrated Advisors Network, LLC (“Integrated” or “the Firm”). Integrated was founded in 2015 and is an SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. Andersen Capital Management is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Peter Andersen is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a 5  percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is 7  compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should 9  consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third party portfolio manager (the “Third Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Advisor Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial 10  practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest 13  can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Warrants • U.S. government securities • Options contracts (including limited use for hedging or income strategies, where appropriate) Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. 14  Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. 15  Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Andersen’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management The Advisor’s fees are generally not negotiable, although the Advisor reserves the right to negotiate its fees. Although the Advisory Service Agreement is an ongoing agreement and adjustments may be required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance. The Advisor’s Fee is generally 1%. Performance Fees The Advisor may also charge a performance-based fee (the “Incentive Fee”) equal to a percentage of the realized and unrealized appreciation of the net asset value (“NAV”) of the client’s account (as reasonably determined in good faith by Advisor and as adjusted for any withdrawals or additions to the client’s account). Incentive Fees will only be charged to clients who meet the definition of “qualified client” under Rule 205-3(d) of the Investment Advisers Act of 1940 (the “Advisers Act”), as amended. All performance fee arrangements will be in accordance with Rule 205-3 under the Advisers Act. The Incentive Fee for the relevant period is negotiable and shall be described more fully in each Investment Management Agreement. Please refer to Item 6: Performance-Based Fees and Side-By-Side Management below for additional information about performance-based fees. Fee Billing Investment management fees will be billed quarterly in advance or arrears. Account values are based on pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. 16  Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amounts due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The clients of the Adviser will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Andersen’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Andersen fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the 17  funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. 18  Item 6 – Performance Fees As noted under Item 5: Fees and Compensation, in addition to or in lieu of Asset-Based Advisory Fees, the Advisor may charge performance-based fees (i.e., Incentive Fees) to certain clients. Such Incentive Fees will only be charged to clients who meet the definition of “qualified client” as defined in Rule 205-3(d) of the Advisers Act. All such fees will only be charged in accordance with the provisions of Rule 205-3 of the Advisers Act. Specifically, the Advisor may charge a periodic (either a quarterly or an annual) Incentive Fee equal to a percentage of the realized and unrealized appreciation of the NAV of the client’s account (as reasonably determined in good faith by the Advisor and as adjusted for any withdrawals from or additions to the account made during the period) as of the end of the immediately preceding period, as adjusted for withdrawals from and additions to the account during the period. The Incentive Fee is negotiable and may vary by account as detailed in each Investment Management Agreement. Performance-based compensation payable to the Advisor may be larger than otherwise would be the case if the fee was only an Asset-Based Advisory Fee because the amount of the Incentive Fee will be based on the account’s performance (which includes unrealized and realized gains and losses). Performance-based fee arrangements may result in a conflict of interest because the receipt of such performance-based compensation may create an incentive for the Advisor to (1) make investments that are riskier or more speculative than would be the case in the absence of a performance-based fee structure and (2) use margin and/or leverage in the client’s account. Such fee arrangements also may create an incentive for the Advisor to favor higher fee-paying accounts over other accounts in the allocation of investment opportunities and could cause the portfolio manager to devote a disproportionate amount of time to the management of accounts that pay performance-based fees. The Advisor’s side-by-side management of accounts that are charged an Asset-Based Advisory Fee and accounts that are charged an Incentive Fee is governed by the Advisor’s internal policies and procedures, which are designed and implemented to ensure that all clients are treated fairly and equitably, and to prevent the conflicts described above from influencing the allocation of investment opportunities among clients. Performance-based fee structures could also create an incentive for the Advisor to overvalue certain assets held by clients. The Advisor has adopted policies designed to promote fair, accurate and current valuations of securities and portfolios. The Advisor utilizes, to the fullest extent possible, the most recent prices reported by the qualified custodians and/or largest securities exchange on which such securities are traded for timely valuation information for clients’ securities and portfolios. Item 7 – Types of Clients Description The Adviser provides services to institutions, individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates or charitable organizations and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated provide services to other types of clients than are disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser generally requires that the client represents and warrants that the value of their account initially is at least $50,000. At the Adviser’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. 19  Item 8 – Methods of Analysis, Investment Strategies & Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Advisor Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. 20  Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Inverse ETF – Inverse ETFs are investment products designed to provide returns that are the opposite of the performance of a stated market index or benchmark on a daily basis. Adviser may use ETFs on a limited, short- term or tactical basis to manage market exposure or express short-term market views. Risk: Inverse ETFs reset daily and are subject to compounding effects, which may cause performance over periods longer than one trading day to differ materially from the inverse of the performance of the underlying index. These investments involve heightened risk, including increased volatility, tracking error, and the potential for rapid or significant losses, and are generally not appropriate for long-term investment strategies. Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Pooled Investment Vehicles and Alternative Allocations – In connection with client portfolios that obtain exposure to alternative investments through pooled investment vehicles, the Adviser relies on investment selection, allocation methodologies, and portfolio construction processes implemented at the fund level by the applicable fund sponsor or manager, which may include the use of proprietary or third-party models. The Adviser does not independently construct, control, or replicate such models and does not manage the day-to-day investment decisions of the pooled investment vehicle. As a result, the Adviser’s ability to influence investment outcomes within these vehicles is limited, and performance is dependent on the methodologies, assumptions, and risk management practices employed by the fund sponsor or manager. Risk: Investments in pooled investment vehicles that utilize proprietary or third-party models involve additional risks, including the risk that model assumptions, data inputs, or methodologies may be incorrect, incomplete, or fail to account for changing market conditions. Because the Adviser does not control or independently validate such models and has limited influence over fund-level investment decisions, clients may experience significant losses, limited liquidity, or outcomes that differ materially from expectations based on traditional asset allocation or risk management approaches. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental 21  part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. 22  Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. 23  Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes 24  in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs 25  from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You 26  can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. 27  Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. 28  Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. 29  However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or 30  continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific 31  period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. 32  Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. 33  Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Advisor Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Advisor Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IAR of Andersen Capital Management. Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 34  8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser Other Affiliations Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Advisor receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. 35  Integrated/Andersen Capital Management engages in lead generation and marketing activities in collaboration with third-party promoters, media platforms, or financial content creators. We are affiliated with and receive referrals from individuals or entities that are not registered investment advisers but may act as promoters or endorsers of our services. These relationships are structured to comply with the SEC’s Marketing Rule (Rule 206(4)-1) and applicable disclosure requirements. These individuals or entities can receive cash or non-cash compensation for referring prospective clients to us. All such arrangements are disclosed to clients at the time of engagement, including the nature of the relationship, compensation terms, and any material conflicts of interest that may arise. Further, we may recommend third-party custodians or technology providers with whom we have business relationships. These affiliations do not influence the advice we provide to clients. Clients are encouraged to review the disclosures provided at the time of referral and to ask questions about any relationship that may influence our recommendations. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. 36  Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. 37  Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, • • • • 38  • the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. 39  Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. 40  In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher 41  commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests 42  always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the advisory Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. 43  Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. 44  Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 – Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between 45  them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. 46  Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions 47  to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. 48  Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 49 

Item 1 – Cover Page Archer Bay Capital Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 1990 Main Street, Suite 750 Sarasota, FL 34236 (617) 453-8789 www.archerbaycapital.com March 31, 2026 This brochure provides information about the qualifications and business practices of Archer Bay Capital, LLC. If you have any questions about the contents of this brochure, please contact us at (617) 453-8789 or by email at: tcampbell@archerbaycapital.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at (855) 729-4222 or compliance@integratedadvisorsnetwork.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfosec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training.  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC, has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC, for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Page ...................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................4 Item 4 – Advisory Business ........................................................................................................................................5 Item 5 – Fees & Compensation ................................................................................................................................ 16 Item 6 – Performance Fees ....................................................................................................................................... 19 Item 7 – Types of Clients ......................................................................................................................................... 20 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................................. 20 Item 9 – Disciplinary Information ............................................................................................................................ 33 Item 10 – Other Financial Industru Activities and Affiliations ................................................................................ 33 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................... 35 Item 12 – Brokerage Practices .................................................................................................................................. 35 Item 13 –Review of Accounts .................................................................................................................................. 41 Item 14 – Client Referrals and Other Compensation ............................................................................................... 43 Item 15 - Custody ..................................................................................................................................................... 44 Item 16 – Investment Discretion .............................................................................................................................. 45 Item 17 Voting Client Securities .............................................................................................................................. 46 Item 18 – Financial Information ............................................................................................................................... 47 4  Item 4 – Advisory Business Description of Firm Archer Bay Capital, LLC, is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter (“the Adviser”, “Associate(s)” or “Archer Bay Capital”). Integrated Advisors Network, LLC, (“Integrated” or “the Firm”) was founded in 2015 and is an SEC-registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. Archer Bay is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Terri Campbell and Kerstin Ramstrom are Investment Adviser Representatives (“IARs”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. 5  Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. 6  It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. - 7  Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected 8  from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non- affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary 9  investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. 10  EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the 11  client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that 12  manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Archer Bay through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Archer Bay may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. There is an inherent conflict of interest for Archer Bay whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Archer Bay or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Archer Bay nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Archer Bay or use the services of Archer Bay. Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) 13  Educational Seminars & Workshop Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. 14  Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, 15  and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees & Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Archer Bay’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. 16  Investment Management Investment Management Services Fee Calculations The Adviser bases its range of fees as a percentage of assets under management. Although the Investment Management Agreement is an ongoing agreement, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. The investment management fees are negotiable at the sole discretion of the Adviser and fees for comparable services may be available from other sources. The standard Investment Management Services annual fee will be charged as a percentage of assets under management. Assets Under Management Annual Fee Up to $5,000,000 0.75% $5,000,001 to $10,000,000 0.65% Over $10,000,000 0.55% Note: Lower fees for comparable services can at times be available from other sources. Employee Benefit Plan Services Fees Note: Employee Benefit Retirement Plan Services annual fees are charged as a percentage of assets within the plan, according to the above-quoted fees for Investment Management Services fees, for ongoing management of assets. For a review of plans that do not include management of assets, a negotiable fixed fee will be charged. Investment Review Fees Investment Reviews will generally be offered on a fixed fee basis. Fees are negotiable and must be paid by electronic funds transfer or by check at the end of the service; cash is not accepted. Financial Planning Fees Financial Planning will generally be offered on a fixed fee basis. Fees are negotiable and must be paid by electronic funds transfer or by check; cash is not accepted. Fee Billing Investment management fees are billed quarterly, in advance based on the total market value of the account as shown on the custodial portfolio statement. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) The client’s custodian will deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated. Clients 17  who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Employee Benefit Plan Services Fee Billing Employee Benefit Plan Services Billing follows the same procedures as “Investment Management Account Billing,” above for management of assets. Please refer to that section, for billing specifics. For an Investment Review of an Employee Benefit Plan, a negotiable fixed fee applies. Investment Review Fee Billing Clients will receive an invoice for Investment Review fees due upon the delivery of the financial plan and a review of results with the client. Payment is due within 30 days of invoice receipt; cash is not accepted. Financial Planning Fee Billing If a Financial Planning fixed fee program is chosen, clients will receive an invoice for the delivery of their financial plan and a review of results with the client. Fees for this service may be paid by electronic funds transfer or check. Fees are negotiable and are payable within 30 days of invoice receipt. Integrated Fee Disclosure The clients of Archer Bay Capital will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Archer Bay Capital’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Archer Bay Capital’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the 18  funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. 19  Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients Description The Advisor provides services to institutions, individuals, high net worth individuals, foundations and endowments, businesses, and non-profit organizations. Client relationships vary in scope and length of service. Other advisory groups of Integrated provide services to other types of clients than is disclosed herein. Account Minimums There is no minimum account size for Archer Bay Capital’s fee-based financial planning or investment review services. There is no account minimum for investment management accounts and fees are negotiable. The annual investment management fee includes financial planning services at no additional charge. There are no ongoing contribution requirements for client accounts. Other advisory groups of Integrated have minimum account sizes. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Advisor Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. 20  Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. 21  Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. 22  Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. 23  Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. 24  Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, 25  increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were 26  issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, 27  and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff 28  were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides 29  for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. 30  Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. 31  - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. 32  It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced settled charges against Integrated for violations of the Marketing Rule under the Advisers Act. Integrated was censured, ordered to cease and desist from further violations, and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Advisor Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Advisor Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Archer Bay Capital. 33  Integrated is an independent registered investment adviser that provides only investment advisory services. Integrated does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), insurance company or agency, 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Advisor receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation 34  for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Archer Bay Capital and its associated persons do not have any other financial industry activities or affiliations. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. 35  Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. 36  Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) 37  Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate 38  securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most 39  favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of 40  securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 –Review of Accounts No less than annually, as indicated herein and within each client's executed Investment Management Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client 41  financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the advisory Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. 42  Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated 43  or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, 44  3. the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types 45  of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. 46  It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 47 

Item 1- Cover Sheet Auctum Wealth Management Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 41 Elderwood Lane Sharpsburg, GA 30277 (770) 783-6663 www.auctumwealth.com March 31, 2026 This brochure provides information about the qualifications and business practices of Auctum Wealth Management, LLC. If you have any questions about the contents of this brochure, please contact us at (770) 783-6663, or by email at tom.king@auctumwealth.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729- 4222 The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training.  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1- Cover Sheet ....................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................4 Item 4 – Advisory Business ........................................................................................................................................5 Item 5 – Fees and Compensation .............................................................................................................................. 17 Item 6 – Performance Fees ....................................................................................................................................... 20 Item 7 – Types of Clients ......................................................................................................................................... 21 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................................. 21 Item 9 – Disciplinary Information ............................................................................................................................ 35 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................ 35 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................... 37 Item 12 – Brokerage Practices .................................................................................................................................. 39 Item 13 – Review of Accounts ................................................................................................................................. 44 Item 14 – Client Referrals and Other Compensation ............................................................................................... 45 Item 15 - Custody ..................................................................................................................................................... 46 Item 16 – Investment Discretion .............................................................................................................................. 47 Item 17 – Voting Client Securities ........................................................................................................................... 47 Item 18 – Financial Information ............................................................................................................................... 49 4  Item 4 – Advisory Business Description of Firm Auctum Wealth Management LLC is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter “the Adviser”, “Associate” or “Auctum Wealth Management”. Integrated Advisors Network, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. Auctum Wealth Management is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Tom King is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a 5  percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is 7  compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should 9  consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. Auctum does not participate in this service. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third-Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial 10  practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Adviser through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Auctum Wealth Management may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. 13  There is an inherent conflict of interest for Acutum Wealth Management whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Auctum Wealth Management or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of Auctum Wealth Management. Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Educational Seminars & Workshop Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third 14  party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. 15  Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. 16  Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Auctum Wealth Management’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management The Adviser bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected quarterly in arrears. The investment management fees are negotiable at the sole discretion of the Adviser and fees for comparable services may be available from other sources. 17  Annualized Investment Management Fees Incremental Account Value From $0 $500,001 $1,000,001 $2,000,001 $5,000,001 Incremental Account Value To $500,000 $1,000,000 $2,000,000 $5,000,000 over Annual Percentage Fee 1.80% 1.50% 1.25% 1.00% 0.85% If the portfolio management agreement is executed at any time other than the first day of the calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which you are a client. Our advisory fee is negotiable, depending on individual client circumstances. At our discretion, we may combine the account values of family members living in the same household to determine the applicable advisory fee. For example, we may combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts. Combining account values may increase the asset total, which may result in your paying a reduced advisory fee based on the breakpoints available in our fee schedule stated above. Financial Planning Fees We charge a fixed fee for financial planning services, which generally ranges between $1500 - $3000. The fee is negotiable depending upon the complexity and scope of the plan, your financial situation, and your objectives. We do not require you to pay fees six or more months in advance and more than $500. Should the engagement last longer than six months between acceptance of financial planning agreement and delivery of the financial plan, any prepaid unearned fees will be promptly returned to you less a pro rata charge for bona fide financial planning services rendered to date. At our discretion, we may offset our financial planning fees to the extent you implement the financial plan through our Portfolio Management Service. You may terminate the financial planning agreement upon 30 days’ written notice to our Firm. If you have pre- paid financial planning fees that we have not yet earned, you will receive a prorated refund of those fees. If financial planning fees are payable in arrears, you will be responsible for a prorated fee based on services performed prior to termination of the financial planning agreement. Fee Billing Investment management fees will be billed quarterly, in arrears, based on an average daily balance. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) 18  Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The clients of Auctum Wealth Management will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Auctum Wealth Management’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Auctum Wealth Management’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. 19  Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both 20  performance-fee accounts and asset-based accounts (side-by-side management), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients Description The Adviser provides services to individuals and high net worth individuals. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than those disclosed herein. Account Minimums The Adviser in general does not require a minimum dollar amount to open and maintain an advisory account; however, we have the right to terminate your Account if it falls below a minimum size which, in our sole opinion, is too small to manage effectively. Other advisory groups of Integrated have minimums or may not have any minimum size account. We may also combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts to meet the stated minimum. Clients will be required to sign investment advisory agreements (and/or other contractual arrangements) that, among other things, set forth the nature and scope of our investment advisory and management authority, specific services, and the investment objectives, guidelines, and restrictions applicable to the management of client accounts. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Advisor Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. 21  Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental 22  part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market 23  corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay 24  current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform 25  accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. 26  Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange 27  Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. 28  Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. 29  Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. 30  However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or 31  continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific 32  period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. 33  Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. 34  Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced settled charges against Integrated for violations of the Marketing Rule under the Advisers Act. Integrated was censured, ordered to cease and desist from further violations, and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Advisor Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Advisor Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Auctum Wealth Management. Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 35  9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Advisor receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Insurance Services Auctum Wealth Management and/or certain associated persons of Auctum Wealth Management may sell insurance products to advisory clients. Some Associates are licensed as independent insurance agents through non-affiliated insurance companies offering fixed, fixed index, variable annuities, life, or long-term care universal life or other insurance products, and insurance services clients may decide to use Integrated for financial planning or investment 36  advisory services. In these capacities, Integrated Advisor Representatives can recommend to firm clients and receive separate, yet customary, commission compensation, including bonuses and trail commissions, resulting from the purchases and sales of these products from the insurance agencies with whom they are presently or with whom they may become appointed in the future in addition to their compensation from Integrated. Such commissions and advisory fees are separate from the firm's advisory fees and Agreements, and clients are under no obligation, contractually or otherwise, to purchase insurance products or receive investment advice through insurance-licensed Associates in their capacities as insurance agents and/or Integrated Advisor Representatives. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell 37  specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. 38  Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services 39  Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar 40  amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), 41  Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. 42  Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. 43  Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the advisory Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. 44  After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. 45  Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because 46  one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. 47  Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake 48  minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. 49  Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 50 

Item 1 – Cover Sheet B&B Strategic Management Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 225 N Bennett St Suite F Southern Pines NC 28387 257 Haywood Rd 2nd Floor Unit 201 Asheville, NC 28806 www.bbstrategic.com March 31, 2026 This brochure provides information about the qualifications and business practices of B&B Strategic Management. If you have any questions about the contents of this brochure, please contact us at (910) 751- 0848, or by email at jgalloway@bbstrategic.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, LLC, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) 2  Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................4 Item 4 – Advisory Business ........................................................................................................................................5 Item 5 – Fees and Compensation .............................................................................................................................. 17 Item 6 – Performance Fees ....................................................................................................................................... 20 Item 7 – Types of Clients ......................................................................................................................................... 20 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................................. 21 Item 9 – Disciplinary Information ............................................................................................................................ 21 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................ 34 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................... 37 Item 12 – Brokerage Practices .................................................................................................................................. 38 Item 13 – Review of Accounts ................................................................................................................................. 43 Item 14 – Client Referrals and Other Compensation ............................................................................................... 45 Item 15 - Custody ..................................................................................................................................................... 46 Item 16 – Investment Discretion .............................................................................................................................. 47 Item 17 – Voting Client Securities ........................................................................................................................... 47 Item 18 – Financial Information ............................................................................................................................... 49 4  Item 4 – Advisory Business Description of Firm B&B Strategic Management is a dba of the registered entity Integrated Advisors Network. LLC, collectively hereinafter “the Advisor”, “Associate” or “B&B”. Integrated Advisors Network. LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. B&B Strategic Management is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Janet Galloway is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, 5  and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is 7  compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should 9  consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial 10  practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning B&B through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. B&B may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. 13  There is an inherent conflict of interest for B&B whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. B&B or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of B&B. Wealth Coaching, Second Opinions & Financial Analysis Fees B&B may provide coaching services that typically do not include investment advisory or management services, financial planning services, nor the review or monitoring of a client’s investment portfolio. The Adviser may recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Adviser. If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. It remains the client’s responsibility to promptly notify the Adviser if there is ever any change in his/her/its situation for the purpose of reviewing/evaluating/revising the Adviser’s previous recommendations and/or services. Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Educational Seminars & Workshop Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to 14  schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. 15  As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to 16  be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of B&B’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. 17  Investment Management The Advisor bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance therefore at termination any unearned fees as determined on a pro rata basis for the portion of the quarter completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Advisor and fees for comparable services may be available from other sources. The Advisor’s Fee can range from .75% through 2.0%, depending upon the passive or active nature of the portfolio. Financial Planning Fees Financial Planning for clients under management and for complex situations is provided under a fixed fee arrangement agreed upon at the first meeting. Fifty percent of the fee is payable in advance, before the financial planning process is started. The remaining fifty percent is payable at the end of the engagement. Wealth Coaching, Second Opinions & Financial Analysis Fees B&B Strategic Management provides a range of education, coaching and analysis services including "second opinions" on existing investment portfolios. These services are provided based on an hourly rate ranging between $125 - $250. An estimate of project cost is made before the project is started. Fifty percent of the fee is payable in advance, and the balance is payable at the end of the engagement. Fee Billing Investment management fees will be billed quarterly in advance. For advance fee billing accounts, we invoice you before the three-month billing period has begun, based on the asset value of your account on the last day of the previous quarter. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The clients of B&B will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the 18  individual brochure for each advisory group for specific details. B&B’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that B&B’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) 19  Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients Description The Advisor provides services to institutions, individuals, high net worth individuals, pension and profit- sharing plans, trusts, estates or charitable organizations and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated provide services to other types of clients than is disclosed herein. 20  Account Minimums To open and maintain a portfolio management account, the Advisor generally requires that the client represents and warrants that the value of their account initially is at least $50,000. At the Advisor’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum account size. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Advisor Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an 21  accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. 22  When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. 23  The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. 24  Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the 25  risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, 26  increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by 27  revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. 28  Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the 29  same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. 30  Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price 31  before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. 32  The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for 33  all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. 34  On September 9, 2024, the SEC announced settled charges against Integrated for violations of the Marketing Rule under the Advisers Act. Integrated was censured, ordered to cease and desist from further violations, and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Advisor Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Advisor Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of B&B. Integrated is an independent registered investment adviser that provides only investment advisory services. Integrated does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), insurance company or agency, 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's 35  services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Advisor receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Insurance Services B&B Strategic Management and/or certain associated persons of B&B Strategic Management sell insurance products to advisory clients through B&B Strategic Insurance. Some Associates are licensed as independent insurance agents through non-affiliated insurance companies offering fixed, fixed index, variable annuities, life, or long-term care universal life or other insurance products, and insurance services clients may decide to use Integrated for financial planning or investment advisory services. In these capacities, Integrated Advisor Representatives can recommend to firm clients and receive separate, yet customary, commission compensation, including bonuses and trail commissions, resulting from the purchases and sales of these products from the insurance agencies with whom they are presently or with whom they may become appointed in the future in addition to their compensation from Integrated. Such commissions and advisory fees are separate from the firm's advisory fees and Agreements, and clients are under no obligation, contractually or otherwise, to purchase insurance products or receive investment advice through insurance-licensed Associates in their capacities as insurance agents and/or Integrated Advisor Representatives. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of 36  the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. 37  This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. 38  While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access 39  to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, 40  and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most 41  favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products 42  and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, 43  a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the advisory Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. 44  As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. 45  Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. 46  Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile 47  and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details . 48  Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, 49  bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 50 

Item 1 – Cover Sheet BURNS BLACKBURN GROUP Form ADV Part 2A – Firm Brochure (CRD # 171991/ SEC #801-96203) 2100 Palomar Airport Road Suite 214-11 Carlsbad, CA 92011 (760) 456-9526 curtis@burnsblackburngroup.com todd@burnsblackburngroup.com March 31, 2026 This brochure provides information about the qualifications and business practices of Burns- Blackburn Group, Inc. If you have any questions about the contents of this brochure, please contact us at (760) 456- 9526, or by email at curtis@burnsblackburngroup.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ...............................................................................................................................................1 Item 2 – Material Changes ......................................................................................................................................2 Item 3 – Table of Contents ......................................................................................................................................4 Item 4 – Advisory Business ....................................................................................................................................5 Item 5 – Fees and Compensation .......................................................................................................................... 17 Item 6 – Performance Fees .................................................................................................................................... 20 Item 7 – Types of Clients ...................................................................................................................................... 21 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................................... 21 Item 9 – Disciplinary Information ......................................................................................................................... 35 Item 10 – Other Financial Industry Activities and Affiliations ............................................................................. 35 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................ 37 Item 12 – Brokerage Practices .............................................................................................................................. 39 Item 13 – Review of Accounts .............................................................................................................................. 44 Item 14 – Client Referrals and Other Compensation ............................................................................................ 44 Item 15 - Custody .................................................................................................................................................. 46 Item 16 – Investment Discretion ........................................................................................................................... 48 Item 17 – Voting Client Securities ........................................................................................................................ 48 Item 18 – Financial Information............................................................................................................................ 50 4  Item 4 – Advisory Business Description of Firm Burns-Blackburn Group Inc. is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter (“the Advisor” “Associate” or “Burns-Blackburn”). Integrated Advisors Network, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. Burns-Blackburn Group Inc. is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Todd Blackburn and Curtis Burns are Investment Adviser Representatives (“IARs”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a 5  percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Adviser Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is 7  compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should 9  consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third-Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial 10  practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Adviser Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Adviser does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Adviser has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred adviser we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Burns-Blackburn through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Burns- Blackburn may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. 13  There is an inherent conflict of interest for Burns-Blackburn whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Burns-Blackburn or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of Burns-Blackburn Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Educational Seminars & Workshop Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third 14  party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. 15  Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. 16  Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Burns-Blackburn’s Form ADV Part 2A Brochure, the applicable Adviser Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management The Adviser bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance therefore at termination any unearned fees as determined on a pro rata basis for the portion of the month completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Adviser and fees for comparable services may be available from other sources. The fee varies from 40 basis points (.40%) up to 150 basis points (1.50%). In certain instances, the Firm may charge a fixed fee for investment management and wealth management services. These fees are negotiable but generally range from $1,000 to $30,000 on a fixed fee basis. 17  FEES Incremental Account Annual Percentage Fee Value From $0 Annualized Investment Management Fees Incremental Account Value To $100,000 1.50% $100,001 $250,000 1.25% $250,001 $500,000 1.00% $500,001 $1,000,000 0.90% $1,000,001 $2,000,000 0.75% $2,000,001 $5,000,000 0.60% $5,000,001 $10,000,000 0.50% $10,000,001 $25,000,000 0.40% $25,000,001 and above Negotiable Financial Planning Fees and Retirement Consulting Fees Burns-Blackburn generally charges as fixed project-based fee to provide clients with retirement plan consulting services. Each engagement is individually negotiated and tailored to accommodate the needs of the individual plan sponsor, as memorialized in the Agreement. These fees vary, based on the scope of the services to be rendered. In those situations where Burns-Blackburn has agreed to manage a plan’s assets, the Firm may also charge an annual asset-based of 50 and 150 basis points (0.50% – 1.50%), depending upon the amount of assets to be managed. Financial Planning for clients, which includes complex situations, is provided under a fixed fee arrangement agreed upon at the first meeting and billed monthly. These services can either be provided based on a range of $250-$2000 fixed fee or Burns-Blackburn may charge a $200 hourly fee for consultation and planning. FINANCIAL PLANNING Portfolio/Investments/Review $250 Retirement/Financial/Planning Hourly/Consulting/and Planning $250 – $2000 $200 per hour Fee Billing Investment management fees will be billed quarterly in advance. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) 18  Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosures The clients of Burns-Blackburn will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Burns-Blackburn’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Burns-Blackburn’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. 19  Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both 20  performance-fee accounts and asset-based accounts (side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients Description The Adviser provides services to institutions, individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates or charitable organizations and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated provide services to other types of clients than are disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser generally requires that the client represents and warrants that the value of their account initially is at least $200,000. At the Adviser’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisers. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. 21  ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. 22  Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. 23  Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. 24  Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques 25  are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple 26  intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more 27  cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder 28  the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs 29  may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant 30  potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these 31  investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below 32  the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from 33  losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. 34  Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Burns-Blackburn. Integrated is an independent registered investment adviser that provides only investment advisory services. Integrated does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), insurance company or agency, 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. 35  Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Registered Representative of Broker-Dealer Integrated is not registered and does not intend to register as a broker-dealer. Still, in connection with their approved outside business activities, some Associates are Registered Representatives (“RRs”) of non-affiliated broker- dealers, Members of FINRA/SIPC. Associates with these unaffiliated broker-dealers can provide brokerage services as an RR of the unaffiliated broker-dealer firm. When acting in the capacity of an RR, the Associates will sell, for commissions, general securities products and will receive commission-based compensation in connection with the purchase and sale of such securities, including 12b-1 fees for the sale of investment company products. If your Adviser Representative offers brokerage products as an RR through their unaffiliated broker-dealer, they are not acting in a brokerage capacity or on behalf of Integrated concerning the services provided under our Agreement(s). Integrated is not involved in the transaction and receives no compensation for the Associate's outside business activity. Associates who provide brokerage services through unaffiliated broker-dealers are independent contractors of such companies. Any compensation earned by these individuals in their capacities as RRs is separate, in addition to, and not related to our advisory fees or Agreement to provide advisory services. Clients are under no obligation to use the firm's Associates’ services in this different capacity as broker-dealer employees. 36  Insurance Services Burns-Blackburn and/or certain associated persons of Burns-Blackburn may sell insurance products to advisory clients. Some Associates are licensed as independent insurance agents through non-affiliated insurance companies offering fixed, fixed index, variable annuities, life, or long-term care universal life or other insurance products, and insurance services clients may decide to use Integrated for financial planning or investment advisory services. In these capacities, Integrated Adviser Representatives can recommend to firm clients and receive separate, yet customary, commission compensation, including bonuses and trail commissions, resulting from the purchases and sales of these products from the insurance agencies with whom they are presently or with whom they may become appointed in the future in addition to their compensation from Integrated. Such commissions and advisory fees are separate from the firm's advisory fees and Agreements, and clients are under no obligation, contractually or otherwise, to purchase insurance products or receive investment advice through insurance-licensed Associates in their capacities as insurance agents and/or Integrated Adviser Representatives. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose 37  securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in 38  such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, • 39  the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client 40  accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. 41  Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. 42  While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account 43  to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the advisory Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate 44  information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and 45  Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the 46  qualified custodian (e.g., deduction of advisory fees and, if applicable, client directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. 47  Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions 48  to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. 49  Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 50 

Item 1 – Cover Sheet Candid Financial Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 13619 62nd Avenue NE Kirkland, WA 98034 (206) 941-7598 candidfinancial.com March 31, 2026 This brochure provides information about the qualifications and business practices of Candid Financial, LLC. If you have any questions about the contents of this brochure, please contact us at (206) 941-7598, or by email at sue@candidfinancial.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfo@sec.gov. Integrated Advisors Network, LLC, is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Frm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ................................................................................................................................................1 Item 2 – Material Changes ........................................................................................................................................2 Item 3 – Table of Contents .......................................................................................................................................4 Item 4 – Advisory Business ......................................................................................................................................5 Item 5 – Fees and Compensation ............................................................................................................................ 16 Item 6 – Performance Fees ..................................................................................................................................... 17 Item 7 – Types of Clients........................................................................................................................................ 19 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................................ 19 Item 9 – Disciplinary Information .......................................................................................................................... 33 Item 10 – Other Financial Industry Activities and Affiliations .............................................................................. 33 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Training ........................ 35 Item 12 – Brokerage Practices ................................................................................................................................ 37 Item 13 – Review of Accounts ............................................................................................................................... 42 Item 14 – Client Referrals and Other Compensation .............................................................................................. 43 Item 15 - Custody ................................................................................................................................................... 44 Item 16 – Investment Discretion ............................................................................................................................. 46 Item 17 – Voting Client Securities ......................................................................................................................... 47 Item 18 – Financial Information ............................................................................................................................. 48 4  Item 4 – Advisory Business Description of Firm Candid Financial, LLC, is a dba of the registered entity Integrated Advisors Network LLC, collectively hereinafter “the Adviser”, “Associate” or “Candid Financial”. Integrated Advisors Network, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. Candid Financial is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Susan Katz and Amanda Klug are Investment Adviser Representatives (“IARs”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a 5  percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is 7  compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should 9  consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial 10  practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning IAR may provide ongoing investment-related guidance and general financial discussions as part of the advisory relationship. These discussions may include topics such as retirement considerations, cash flow awareness, education funding concepts, or tax considerations as they relate to investment decisions. Such guidance is provided in connection with investment management services and does not constitute a separate or comprehensive financial planning engagement. Other IARs of Integrated may offer financial planning. Educational Seminars & Workshop Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to 13  schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. 14  As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to 15  be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Candid Financial’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. 16  Investment Management The Adviser bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in arrears. The investment management fees are non-negotiable. The account fee is 1% annually. Fee Billing Investment management fees will be billed and deducted quarterly immediately following the quarter. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The clients of Candid Financial will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Candid Financial’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Candid Financial’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity 17  products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently 18  depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (side-by-side management), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients Description The Adviser provides services to institutions, individuals, high net worth individuals, pension and profit-sharing plans, charitable organizations, and corporate and business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser does not have an account minimum. Other advisory groups of Integrated have minimum account sizes. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the 19  accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price 20  per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our 21  firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since 22  they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks 23  may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring 24  the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or 25  financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical 26  compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. 27  Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically 28  unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. 29  Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not 30  backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. 31  Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using 32  AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Candid Financial. 33  Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while 34  focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Candid Financial and its associated persons do not have any other financial industry activities or affiliations. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Training Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell 35  specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. 36  Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • 37  Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than 38  if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than 39  those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. 40  Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Candid Financial does not aggregate orders. Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where 41  trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided 42  by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and 43  Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the 44  qualified custodian (e.g., deduction of advisory fees and, if applicable, client directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. 45  Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions 46  to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. 47  Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 48 

Item 1 – Cover Sheet Capital City Financial Partners, LLC Form Adv Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 6208 Garners Ferry Road, Suite A Columbia, SC 29209 250 Berryhill Road, Suite 510 Columbia, SC 29210 124 Verdae Blvd, Suite 403 Greenville, SC 29607 710 Johnnie Dodds Blvd. Suite 202 Mount Pleasant SC 29464 1200 Ridgefield Boulevard, Suite 261 Asheville, NC 28806 (803) 782-0671 https://capitalcityfinancialpartners.com March 31, 2026 This brochure provides information about the qualifications and business practices of Capital City Financial Partners, LLC. If you have any questions about the contents of this brochure, please contact us at: (803) 782-0671, or by email at: katherine@capitalcityfp.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Capital City added a new office location at 710 Johnnie Dodds Blvd. Suite 202 Mount Pleasant, SC 29464. Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Additionally, Capital City amended their fee schedule to match Integrated’s maximum fee of 2.95%. Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. 2  Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................4 Item 4 – Advisory Business ........................................................................................................................................5 Item 5 – Fees and Compensation .............................................................................................................................. 17 Item 6 – Performance Fees ....................................................................................................................................... 20 Item 7 – Types of Clients ......................................................................................................................................... 20 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................................. 20 Item 9 – Disciplinary Information ............................................................................................................................ 34 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................ 35 Item 11 – Code of Ethics, Participation or Interest In Client Transactions and Personal Trading ........................... 37 Item 12 – Brokerage Practices .................................................................................................................................. 39 Item 13 – Review of Accounts ................................................................................................................................. 44 Item 14 – Client Referrals and Other Compensation ............................................................................................... 45 Item 15 - Custody ..................................................................................................................................................... 47 Item 16 – Investment Discretion .............................................................................................................................. 48 Item 17 – Voting Client Securities ........................................................................................................................... 49 Item 18 – Financial Information ............................................................................................................................... 50 4  Item 4 – Advisory Business Description of Firm Capital City Financial Partners, LLC, is a dba of the registered entity Integrated Advisors Network LLC, collectively hereinafter “the Adviser”, “Associate” or “Capital City”. Integrated Advisors Network, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. Capital City is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. There are several Investment Adviser Representatives (“IARs”) of Integrated Advisors Network, LLC who work for Capital City. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a 5  percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Code Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is 7  compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should 9  consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third-Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial 10  practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Capital City through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Capital City may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. 13  There is an inherent conflict of interest for Capital City whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Capital City or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of Capital City. Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Educational Seminars & Workshop Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third 14  party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. 15  Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. 16  Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Capital City’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management The Advisor bases its range of fees as a percentage of assets under management. Although the Investment Management Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance. The investment management fees are negotiable at the sole discretion of the Advisor and fees for comparable services may be available from other sources. The Advisor’s Fee can range from .3% through 2.95%, depending upon the passive or active nature of the portfolio. In some cases, due to an acquisition of Wall & Co. in 2020, fees are charged quarterly in arrears at the rate of one quarter of the annual fee and are due within the first 15 days following the end of the prior quarter. 17  Financial Planning Fees Financial Planning for clients without $300,000+ under management and for complex situations is provided under a fixed fee arrangement agreed upon at the first meeting and based on an hourly rate ranging between $100 -$250. Fifty percent of the fee is payable in advance, before the financial planning process is started. The remaining fifty percent is payable at the end of the engagement. In some cases, there are flat-fee agreements that are to be paid quarterly. Fee Billing Investment management fees will be billed quarterly in advance or in some cases as indicated in the Investment Management section ay be charged in arrears. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Financial planning fees are able to be deducted from another specified client account as authorized by the investment management agreement or financial planning agreement. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The clients of Capital City will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Capital City’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Capital City’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of 18  mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. 19  Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients Description The Adviser provides services to institutions, individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates or charitable organizations and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated provide services to other types of clients than are disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser generally requires that the client represents and warrants that the value of their account initially is at least $50,000. At the Adviser’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. 20  Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully 21  diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of 22  account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. 23  Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received 24  when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. 25  Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the 26  account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. 27  Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. 28  Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the 29  market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of 30  principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are 31  advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. 32  - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting 33  recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. 34  Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Capital City. Integrated is an independent registered investment adviser that provides only investment advisory services. Integrated does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), insurance company or agency, 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before 35  selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser Registered Representative of Broker-Dealer Integrated is not registered and does not intend to register as a broker-dealer. Still, in connection with their approved outside business activities, some Associates are Registered Representatives (“RRs”) of non-affiliated broker- dealers, Members of FINRA/SIPC. Associates with these unaffiliated broker-dealers can provide brokerage services as an RR of the unaffiliated broker-dealer firm. When acting in the capacity of an RR, the Associates will sell, for commissions, general securities products and will receive commission-based compensation in connection with the purchase and sale of such securities, including 12b-1 fees for the sale of investment company products. If your Adviser Representative offers brokerage products as an RR through their unaffiliated broker-dealer, they are not acting in a brokerage capacity or on behalf of Integrated concerning the services provided under our Agreement(s). Integrated is not involved in the transaction and receives no compensation for the Associate's outside business activity. Associates who provide brokerage services through unaffiliated broker-dealers are independent contractors of such companies. Any compensation earned by these individuals in their capacities as RRs is separate, in addition to, and not related to our advisory fees or Agreement to provide advisory services. Clients are under no obligation to use the firm's Associates’ services in this different capacity as broker-dealer employees. Insurance Services Capital City and/or certain associated persons of Capital City may sell insurance products to advisory clients. Some Associates are licensed as independent insurance agents through non-affiliated insurance companies offering fixed, fixed index, variable annuities, life, or long-term care universal life or other insurance products, and insurance services clients may decide to use Integrated for financial planning or investment advisory services. In these capacities, Integrated Adviser Representatives can recommend to firm clients and receive separate, yet customary, commission compensation, including bonuses and trail commissions, resulting from the purchases and sales of these products from the insurance agencies with whom they are presently or with whom they may become appointed in the future in addition to their compensation from Integrated. Such commissions and advisory fees are separate from the firm's advisory fees and Agreements, and clients are under no obligation, contractually or otherwise, to purchase insurance products or receive investment advice through insurance-licensed Associates in their capacities as insurance agents and/or Integrated Adviser Representatives. Tax Preparation Services CCFP Tax Solutions: CCFP Tax Solutions is a branch of Capital City Financial Partners that provides traditional accounting and tax preparation services. It is anticipated that some of the advisory clients will also be clients of CCFP Tax Solutions. However, clients of Capital City are not required to use the accounting/tax services offered by CCFP Tax Solutions. Capital City does not make any representation that the accounting/tax services are at the lowest cost available, and clients may be able to obtain those services and/or products at a more favorable rate from 36  other firms. The accounting and tax preparation activities provided by these individuals are entirely separate and distinct from the advisory services provided by Integrated Advisors Network. Services provided by CCFP Tax Solutions shall be pursuant to a separate engagement letter between the client and CCFP Tax Solutions and shall be based on the normal fee structure of the CCFP Tax Solutions. Estate Planning Services CCFP Legacy Planning: CCFP Legacy Planning is a branch of Capital City Financial Partners that provides estate planning and document preparation services. It is anticipated that some of the advisory clients will also be clients of CCFP Legacy Planning. The following measures have been implemented to ensure transparency and protect the interests of clients. Use of CCFP Legacy Planning services is optional. Clients are free to select any estate planning provider of their choice. Capital City Financial Partners does not represent that CCFP Legacy Planning offers the lowest-cost estate planning services. Clients may find similar services at more favorable rates from other firms. Estate planning and document preparation services provided by CCFP Legacy Planning are distinct from the investment advisory services offered through Integrated Advisors Network. These services are governed by a separate engagement letter and fee arrangement between the client and CCFP Legacy Planning. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest In Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. 37  Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. 38  Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, • • • • 39  • the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. 40  Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. 41  In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher 42  commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests 43  always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. 44  Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. 45  Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. 46  Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. 47  Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. 48  For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. 49  Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 50 

Copper Crest Capital Form ADV Part 2A Firm Brochure March 31, 2026 Copper Crest Capital (a dba of Integrated Advisors Network, LLC) 5330 Carroll Canyon Rd Suite 100 San Diego, CA 92121 619-350-1944 (phone) 619-937-3705 (fax) firm@coppercrestcapital.com FORM ADV PART 2A – FIRM BROCHURE ITEM 1 – COVER PAGE This Brochure provides information about the qualifications and business practices of Copper Crest Capital. Any questions about the contents of this Brochure should be directed to the Adviser by phone at 619-350-1944 or by email at firm@coppercrestcapital.com. Alternatively, contact the Chief Compliance Officer of Integrated, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call 855-729-4222. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about the Adviser is also available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. Page | 1  Copper Crest Capital Form ADV Part 2A Firm Brochure ITEM 2 – MATERIAL CHANGES ANNUAL UPDATE This section describes material changes to Copper Crest Capital’s Part 2A of Form ADV (a dba of Integrated Advisors Network, LLC since its last annual amendment. In this item, Integrated Advisors Network, LLC ("Integrated" or "the Adviser") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. 729 4222, or You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855 visiting www.adviserinfo.sec.gov. ‑ ‑ MATERIAL CHANGES SINCE THE LAST UPDATE Since our last annual updating amendment on March 31, 2025, the following material changes have been made to this brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Assets Under Management Discretionary $ 5,286,824,594 Non-Discretionary $ 235,737,249 Total $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under Page | 2  Copper Crest Capital Form ADV Part 2A Firm Brochure management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. Page | 3  Copper Crest Capital Form ADV Part 2A Firm Brochure ITEM 3 – TABLE OF CONTENTS Form ADV Part 2A – Firm Brochure .........................1 Item 1 – Cover Page .........................................1 Item 2 – Material Changes ...............................2 Annual Update Error! Bookmark not defined. Material Changes since the last Update Error! Bookmark not defined. Item 3 – Table of Contents ...............................4 Item 4 – Advisory Business ...............................5 Description of the firm .................................5 Types of Advisory Services ............................5 Item 5 – Fees and Compensation ................... 14 Fees ........................................................... 14 Fee Billing .................................................. 14 Integrated Fee Disclosure ........................... 15 Other Fees ................................................. 15 Wrap Fee Program ..................................... 16 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.......................................................... 30 Code of Ethics............................................ 30 Participation or Interest in Client Transactions .............................................. 31 Personal Trading........................................ 31 Item 12 – Brokerage Practices ....................... 32 Preferred Custodians & Brokers-Dealers .... 32 Custodial Support Services......................... 32 Directed Brokerage.................................... 35 Investment Allocation & Trade Aggregation Policy ........................................................ 35 Item 13 – Review of Accounts ........................ 36 Reviews ..................................................... 36 Client Reports ............................................ 36 Item 6 – Performance-Based Fees and Side-By- Side Management .......................................... 16 Item 7 – Types of Clients ................................ 17 Description ................................................ 17 Account Minimums .................................... 17 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................. 17 Method of Analysis .................................... 17 Investment Strategies ................................ 18 Risk of Loss ................................................ 19 Item 9 – Disciplinary Information ................... 28 Item 10 – Other Financial Industry Activities and Affiliations ..................................................... 28 Other Financial Industry Affiliations ........... 30 Item 14 – Client Referrals and Other Compensation ............................................... 37 Client Referrals .......................................... 37 Related Party Referrals .............................. 37 Third-Party Referrals ................................. 37 Other Compensation ................................. 38 Conflicts of Interest ................................... 38 Item 15 – Custody ......................................... 38 Item 16 – Investment Discretion .................... 39 Item 17 – Voting Client Securities .................. 40 Proxy Voting .............................................. 40 Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings ............ 40 Item 18 – Financial Information ..................... 41 Page | 4  Copper Crest Capital Form ADV Part 2A Firm Brochure ITEM 4 – ADVISORY BUSINESS DESCRIPTION OF THE FIRM Copper Crest Capital is a dba of the registered entity Integrated Advisors Network LLC, collectively hereinafter “the Adviser”, “Associate” or Copper Crest Capital. Integrated Advisors Network, LLC (“Integrated” or “the Firm”) was founded in 2015 and is a SEC registered investment advisor. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. TYPES OF ADVISORY SERVICES The Firm is a fee-only investment management and financial planning firm. Integrated does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The investment management services are provided through separately managed accounts for each client. The Adviser does not act as a custodian of client assets, and the client always maintains asset control. The Adviser has discretion of client accounts and places trades for clients under a limited power of attorney. Copper Crest Capital is a dba of both Copper Crest Advisors LLC and Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Jeff Stephenson, Michael Stephenson, Mason Tucker, David Foster and Michael Brown are Investment Adviser Representatives (“IARs”) of Integrated Advisors Network, LLC. The Adviser provides investment services, also known as asset management services. Also, on more than an occasional basis, the Adviser may furnish advice to clients on matters not involving securities, such as financial planning matters. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor Page | 5  Copper Crest Capital Form ADV Part 2A Firm Brochure the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement and IPS. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services Page | 6  Copper Crest Capital Form ADV Part 2A Firm Brochure As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income and Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). Never put our financial interests ahead of yours when making recommendations (give loyal advice). Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - - - - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: Leaving the funds in the employer's/former employer's plan. Cashing out and taking a taxable distribution from the plan. Rolling the funds into an IRA rollover account. • • Moving the funds to a new employer's retirement plan. • • Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: • Determine whether the investment options in your Employer's retirement plan address your needs or whether you Page | 7  Copper Crest Capital Form ADV Part 2A Firm Brochure might wish to consider other investment types: o o Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. Consider plan fees - your current plan may have lower fees than Adviser’s fees: • o o If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. • • • • • • Adviser’s strategy may have a higher risk than your plan's option(s). Your current plan may also offer financial advice. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 72. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. You may be able to take out a loan on your 401(k), but not from an IRA. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. • • General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or Page | 8  Copper Crest Capital Form ADV Part 2A Firm Brochure administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third-Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Advisor Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred-manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. Page | 9  Copper Crest Capital Form ADV Part 2A Firm Brochure In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Assessment assistance of the client’s investment needs and objectives. Investment policy planning assistance. Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. Recommendations on appropriate style allocations. Identification of appropriate managers and investment vehicles suitable for the client’s goals. Evaluation of asset managers and investment vehicles meeting style and allocation criteria. Engagement of selected asset managers and investment vehicles on behalf of the client. • • • • • • • • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment • strategies. Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. Recommendations for account rebalancing, if necessary. • • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. Access to third-party platforms and strategies through the eps platform. • Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third-party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio Page | 10  Copper Crest Capital Form ADV Part 2A Firm Brochure (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the advisor invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Copper Crest Capital through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Copper Crest Capital may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. There is an inherent conflict of interest for Copper Crest Capital whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Copper Crest Page | 11  Copper Crest Capital Form ADV Part 2A Firm Brochure Capital or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of Copper Crest Capital Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: Equities (stocks). Corporate debt securities. Digital Assets / Bitcoin Exchange-traded funds (“ETFs”). Investment company securities - variable life insurance, variable annuities, and mutual fund shares (no-load/ low-load). • • • • • • Warrants. • U.S. government securities. Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Page | 12  Copper Crest Capital Form ADV Part 2A Firm Brochure Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client-imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost- effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2024, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Page | 13  Copper Crest Capital Form ADV Part 2A Firm Brochure Account Type Assets Under Management Discretionary $5,286,824,594 Non-Discretionary $235,737,249 Total $5,522,561,843 ITEM 5 – FEES AND COMPENSATION FEES Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Copper Crest Capital’s Form ADV Part 2A Brochure, the applicable Adviser Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Asset Aggregation Services. The fees the Adviser charges for aggregation services are based on an estimated time commitment multiplied by hourly rates in the range of $200-$500 depending on the nature and complexity of the tasks. These fees are generally estimated and agreed upon at the beginning of each year. This fee and payment terms will be stated in the advisory contract. Clients may also be charged account processing fees to reflect service fees charged by certain automated data providers. If these fees are included in the advisory contract, the Adviser will pass these fees through at their cost. Asset Allocation and Management Services. The Advisor sets a fee structure separately for each client that takes into consideration the number and complexity of accounts, the anticipated client interaction, and the assets under management for the total relationship. The fees are charged as a percentage of assets under management and generally do not exceed 1% annually. All fees and payment terms will be stated in the advisory contract. Special Projects. For special projects, the Adviser generally bills at an hourly rate associated with the individuals that will be doing the work. Such hourly rates will range from $200-$500 per hour. The Adviser will attempt to estimate its time and the resultant fee in a separate engagement letter. The fee and payment terms will be stated in the engagement letter. The above Asset Allocation and Management Services fees, when combined, are subject to a monthly minimum of $500 per client. The fee and payment terms will be stated in the advisory contract. Husband, wife, and related family trusts are generally considered one client for the fee assessment and the minimum fee rule. All fees, including the minimum fee and the aggregation fee, are negotiable. FEE BILLING The Adviser bills all fees monthly, in arrears. The Adviser never requires fees to be paid in advance. Accounts initiated or terminated during a calendar month will be charged a prorated fee. Integrated generally deducts the fees from one or more of the client’s investment accounts. Written authorization to deduct fees from this account (or accounts) is included as part of the advisory contract. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Page | 14  Copper Crest Capital Form ADV Part 2A Firm Brochure Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) The client’s custodian will deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. INTEGRATED FEE DISCLOSURE The clients of Copper Crest Capital will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure of each advisory group for specific details. Copper Crest’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Copper Crest’s fees are the lowest available for similar services. OTHER FEES The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Page | 15  Copper Crest Capital Form ADV Part 2A Firm Brochure Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. WRAP FEE PROGRAM The Adviser does not offer any form of wrap fee program or similar fee structures for its services. Other IARs under other advisory groups at Integrated do offer wrap programs. ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance-based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance-based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Page | 16  Copper Crest Capital Form ADV Part 2A Firm Brochure ITEM 7 – TYPES OF CLIENTS DESCRIPTION The Adviser provides services to high-net-worth individuals, institutions, certain retirement plans, trusts, estates, charitable organizations, corporations or other business entities directly. Client relationships vary in scope and degree of service. Other advisory groups of Integrated provide services to other types of clients. ACCOUNT MINIMUMS While there is no minimum size account or relationship requirement, the Firm does have a minimum monthly fee for investment advisory services as described at Item 5, page 13 of this Brochure. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. METHOD OF ANALYSIS We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Page | 17  Copper Crest Capital Form ADV Part 2A Firm Brochure INVESTMENT STRATEGIES We use one or more of the following investment strategies when providing investment advice to you: Inverse ETF – Inverse ETFs are investment products designed to provide returns that are the opposite of the performance of a stated market index or benchmark on a daily basis. Adviser may use ETFs on a limited, short-term or tactical basis to manage market exposure or express short-term market views. Risk: Inverse ETFs reset daily and are subject to compounding effects, which may cause performance over periods longer than one trading day to differ materially from the inverse of the performance of the underlying index. These investments involve heightened risk, including increased volatility, tracking error, and the potential for rapid or significant losses, and are generally not appropriate for long term investment strategies. Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Pooled Investment Vehicles and Alternative Allocations – In connection with client portfolios that obtain exposure to alternative investments through pooled investment vehicles, the Adviser relies on investment selection, allocation methodologies, and portfolio construction processes implemented at the fund level by the applicable fund sponsor or manager, which may include the use of proprietary or third party models. The Adviser does not independently construct, control, or replicate such models and does not manage the day to day investment decisions of the pooled investment vehicle. As a result, the Adviser’s ability to influence investment outcomes within these vehicles is limited, and performance is dependent on the methodologies, assumptions, and risk management practices employed by the fund sponsor or manager. Risk: Investments in pooled investment vehicles that utilize proprietary or third party models involve additional risks, including the risk that model assumptions, data inputs, or methodologies may be incorrect, incomplete, or fail to account for changing market conditions. Because the Adviser does not control or independently validate such models and has limited influence over fund level investment decisions, clients may experience significant losses, limited liquidity, or outcomes that differ materially from expectations based on traditional asset allocation or risk management approaches. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us Page | 18  Copper Crest Capital Form ADV Part 2A Firm Brochure immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians typically have a default accounting method set for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. RISK OF LOSS Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by Page | 19  Copper Crest Capital Form ADV Part 2A Firm Brochure downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage-backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non- U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, Page | 20  Copper Crest Capital Form ADV Part 2A Firm Brochure and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited Page | 21  Copper Crest Capital Form ADV Part 2A Firm Brochure partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated Page | 22  Copper Crest Capital Form ADV Part 2A Firm Brochure with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open- end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Page | 23  Copper Crest Capital Form ADV Part 2A Firm Brochure Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re- extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange- traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher Page | 24  Copper Crest Capital Form ADV Part 2A Firm Brochure risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre-packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non- diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of Page | 25  Copper Crest Capital Form ADV Part 2A Firm Brochure additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: • • • Risk of losing your entire investment in a relatively short period of time. The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. Specific exercise provisions of a specific option contract may create risks. Regulatory agencies may impose exercise restrictions, which stops you from realizing value. • • Page | 26  Copper Crest Capital Form ADV Part 2A Firm Brochure The option trading risks for options sellers are: • Options sold may be exercised at any time before expiration. • Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. • Writers of Naked Calls risk unlimited losses if the underlying stock rises. • Writers of Naked Puts risk substantial losses if the underlying stock drops. • Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. • Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. • Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are • exercised. Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. • Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. • Other option trading risks are: The complexity of some option strategies is a significant risk on its own. • • Option trading exchanges or markets and options contracts are always open to changes. • Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. Risk of erroneous reporting of exercise value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. • • • Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Page | 27  Copper Crest Capital Form ADV Part 2A Firm Brochure Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. ITEM 9 – DISCIPLINARY INFORMATION Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. Neither Copper Crest Capital nor any of their principals or employees has ever been involved in any legal or disciplinary events related to past or present investment advisory clients. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Integrated at 855.729.4222 or by visiting Copies of disclosure documents are also available by contacting www.integratedadvisorsnetwork.com. ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the supervision of arrangement described above with the IARs of Copper Crest Capital. Page | 28  Copper Crest Capital Form ADV Part 2A Firm Brochure Integrated is an independent registered investment adviser that provides only investment advisory services. Integrated does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: • • broker-dealer, municipal securities dealer, government securities dealer or broker, investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), other investment adviser or financial planner, futures commission merchant, commodity pool operator, or commodity trading adviser, banking or thrift institution, accountant or accounting firm, a lawyer or law firm, insurance company or agency, pension consultant, real estate broker or dealer, and sponsor or syndicator of limited partnerships. • • • • • • • • • Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. However, this IAR’s advisory practice does not utilize promoters for client referrals and does not pay or receive referral compensation in connection with client introductions. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Integrated can also serve as Promoter to the third-party money managers it engages for its Managed Account Solutions (“MAS”) Program services for advisory, administrative, and/or technological services. In this capacity, the Adviser will introduce clients for whom the referred manager's services are suitable and appropriate. In connection with such relationships, Promoter fees can range from 0% to 50% and vary based on the executed Solicitor Agreement. Fees shared will not exceed any limit imposed by any regulatory agency. Clients should refer to their TPM Agreement for exact details and amounts. (Please see Item 14: Client Referrals & Other Compensation for additional details.) Apart from our clients' fees, we do not receive any other economic benefits, including sales awards or prizes. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Page | 29  Copper Crest Capital Form ADV Part 2A Firm Brochure Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser OTHER FINANCIAL INDUSTRY AFFILIATIONS Copper Crest Capital is affiliated, and has common principals, with two other financial services firms: Copper Crest CPAs LLP. Many of the principals of Copper Crest Capital are certified public accountants whose licenses are associated with Copper Crest CPAs LLP (the “CPA Firm”). The CPA Firm provides traditional accounting and tax services as well as estate planning and consulting in the same offices as the Adviser. It is anticipated that some of the advisory clients will also be clients of the CPA Firm. Services provided by the CPA Firm shall be pursuant to a separate engagement letter between the client and the CPA Firm and shall be based on the normal fee structure of the CPA Firm. Copper Crest Insurance Services LLC. Mason Tucker and Michael Stephenson, principals of Copper Crest Capital, are also principals of Copper Crest Insurance Services LLC (the “Insurance Firm”). The Insurance Firm provides brokerage services for property, casualty, commercial, life, health and disability insurance products in the same offices as the Adviser. It is anticipated that some of the Firm’s clients will also be clients of the Insurance Firm. Services provided by the Insurance firm shall be based on the normal commission or fee structure customary for these products and services. Clients are not required to receive services from the CPA Firm, nor are they required to receive services or purchase products from the Insurance Firm, in order to obtain investment advisory services from the Adviser. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING CODE OF ETHICS Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and Page | 30  Copper Crest Capital Form ADV Part 2A Firm Brochure holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. PERSONAL TRADING Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Page | 31  Copper Crest Capital Form ADV Part 2A Firm Brochure Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. ITEM 12 – BROKERAGE PRACTICES PREFERRED CUSTODIANS & BROKERS-DEALERS Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker-dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC- registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • • • • • • • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, personal money management tools such as electronic fund transfer capabilities, dividend reinvestment programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • CUSTODIAL SUPPORT SERVICES Page | 32  Copper Crest Capital Form ADV Part 2A Firm Brochure Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: provides access to client account data (such as duplicate trade confirmations and account statements), facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, publications and conferences on practice management and business succession, and access to employee benefits providers, human capital consultants, and insurance providers. • • • • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research-related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, Page | 33  Copper Crest Capital Form ADV Part 2A Firm Brochure institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker- dealers' services. When this happens, Integrated will make a good-faith allocation between the non-research and research portions of the services received and pay Integrated money ("hard dollars") for the non-research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Page | 34  Copper Crest Capital Form ADV Part 2A Firm Brochure Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. DIRECTED BROKERAGE Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. INVESTMENT ALLOCATION & TRADE AGGREGATION POLICY Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Page | 35  Copper Crest Capital Form ADV Part 2A Firm Brochure Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. ITEM 13 – REVIEW OF ACCOUNTS REVIEWS No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. CLIENT REPORTS At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. Page | 36  Copper Crest Capital Form ADV Part 2A Firm Brochure After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION CLIENT REFERRALS Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. RELATED PARTY REFERRALS As discussed at Item 10 in this Brochure, Copper Crest Capital is closely associated, through ownership and affiliation, to a CPA Firm and an Insurance Firm. Recommendations to clients of the Adviser for services of either of those related entities will provide an indirect benefit to the principals of the Firm. Likewise, a recommendation from the CPA Firm or the Insurance Firm to the Adviser shall result in an indirect benefit to the principals of the CPA Firm and/or the Insurance Firm. Any fees charged by these related entities for services provided are customary and separate from fees charged by the Adviser. THIRD-PARTY REFERRALS Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. For clarity, this IAR’s advisory practice does not pay or receive referral compensation in connection with client introductions. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Page | 37  Copper Crest Capital Form ADV Part 2A Firm Brochure Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non- client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. OTHER COMPENSATION Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. CONFLICTS OF INTEREST The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. ITEM 15 – CUSTODY Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client-directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Page | 38  Copper Crest Capital Form ADV Part 2A Firm Brochure Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: • • • • • • • the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third- party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, Integrated maintains records showing that the third party is not a related party of the Adviser or located at the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. ITEM 16 – INVESTMENT DISCRETION Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: determine the security to buy or sell, determine the amount of security to buy or sell, and determine the timing of when to buy or sell. • • • For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. Page | 39  Copper Crest Capital Form ADV Part 2A Firm Brochure In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. ITEM 17 – VOTING CLIENT SECURITIES PROXY VOTING Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. CLASS ACTION SUITS, CLAIMS, BANKRUPTCIES & OTHER LEGAL ACTIONS & PROCEEDINGS A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have Page | 40  Copper Crest Capital Form ADV Part 2A Firm Brochure been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. ITEM 18 – FINANCIAL INFORMATION Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self-regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. Page | 41 

Item 1 – Cover Sheet Echelon Investment Management Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 408 W 8th Street, Suite 103 Dallas, TX 75208 (214) 232-5974 www.echelonim.com March 31, 2026 This brochure provides information about the qualifications and business practices of Echelon Investment Management, LLC. If you have any questions about the contents of this brochure, please contact us at (214) 232- 5974, or by email at info@echelonim.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfo@sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 - Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) 2  Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 - Material Changes ..........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................4 Item 4 – Advisory Business ........................................................................................................................................5 Item 5 – Fees & Compensation ................................................................................................................................ 17 Item 6 – Performance Fees ....................................................................................................................................... 20 Item 7 – Types of Clients ......................................................................................................................................... 20 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................................. 20 Item 9 – Disciplinary Information ............................................................................................................................ 34 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................ 35 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................... 37 Item 12 – Brokerage Practices .................................................................................................................................. 38 Item 13 – Review of Accounts ................................................................................................................................. 43 Item 14 – Client Referrals and Other Compensation ............................................................................................... 45 Item 15 - Custody ..................................................................................................................................................... 46 Item 16 – Investment Discretion .............................................................................................................................. 47 Item 17 – Voting Client Securities ........................................................................................................................... 48 Item 18 – Financial Information ............................................................................................................................... 49 4  Item 4 – Advisory Business Description of Firm Echelon Investment Management, LLC is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter “the Advisor”, “Associate” or “Echelon”. Integrated Advisors, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. Echelon is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. James Mathis and James Tindall are Investment Adviser Representatives (“IARs”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, 5  and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is 7  compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and - Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should 9  consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial 10  practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Echelon through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Echelon may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. 13  There is an inherent conflict of interest for Echelon whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Echelon or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of Echelon. Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Educational Seminars & Workshop Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third 14  party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. 15  Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. 16  Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees & Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Echelon’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management The Adviser bases its range of fees as a percentage of assets under management. Although the Investment Management Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. The investment management fees are negotiable at the sole discretion of the Adviser and fees for comparable services may be available from other sources. 17  Account Asset Value Equity/Balanced Annual Fee $0 - $1,000,000 1.5% $1,000,000.01 - $2,000,000 .90% $2,000,000.01 + .80% $4,000,000 and up Negotiable Fee Billing Investment management fees will be billed quarterly or monthly in arrears based on the total market value of the account as shown on the Firm’s provided portfolio statement on the last business day of the quarter or month. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The clients of Echelon will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Echelon’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Echelon’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. 18  The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. 19  Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients Description The Adviser generally provides investment advice to investment advisory firms or individual Investment Adviser Representatives (that may be other IARs at Integrated Advisors Network LLC). The Adviser provides services to institutions, individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates or charitable organizations and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser generally requires that the client represents and warrants that the value of their account initially is at least $250,000. At the Adviser’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. 20  Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully 21  diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of 22  account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. 23  Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received 24  when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. 25  Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the 26  account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. 27  Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. 28  Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the 29  market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of 30  principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are 31  advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. 32  - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. - Risk of erroneous reporting of exercise value. - If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting 33  recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. 34  Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Echelon. Integrated is an independent registered investment adviser that provides only investment advisory services. Integrated does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), insurance company or agency, 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. 35  Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser Registered Representative of Broker-Dealer Integrated is not registered and does not intend to register as a broker-dealer. Still, in connection with their approved outside business activities, some Associates are Registered Representatives (“RRs”) of non-affiliated broker- dealers, Members of FINRA/SIPC. Associates with these unaffiliated broker-dealers can provide brokerage services as an RR of the unaffiliated broker-dealer firm. When acting in the capacity of an RR, the Associates will sell, for commissions, general securities products and will receive commission-based compensation in connection with the purchase and sale of such securities, including 12b-1 fees for the sale of investment company products. If your Adviser Representative offers brokerage products as an RR through their unaffiliated broker-dealer, they are not acting in a brokerage capacity or on behalf of Integrated concerning the services provided under our Agreement(s). Integrated is not involved in the transaction and receives no compensation for the Associate's outside business activity. Associates who provide brokerage services through unaffiliated broker-dealers are independent contractors of such companies. Any compensation earned by these individuals in their capacities as RRs is separate, in addition to, and not related to our advisory fees or Agreement to provide advisory services. Clients are under no obligation to use the firm's Associates’ services in this different capacity as broker-dealer employees. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. 36  Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. 37  To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. 38  Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: 39  facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, 40  risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. 41  Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase 42  securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. 43  Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. 44  Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. 45  Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. 46  The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the 47  introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. 48  While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 49 

Item 1 – Cover Sheet Ely Prudent Portfolios Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 40 Philadelphia Drive, Suite 101 Chico, CA 95973 (530) 895-0636 http://elyportfolios.com March 31, 2026 This brochure provides information about the qualifications and business practices of Ely Prudent Portfolios, LLC. If you have any questions about the contents of this brochure, please contact us at: (530) 895-0636, or by email at: gtely@elyportfolios.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ................................................................................................................................................1 Item 2 – Material Changes .......................................................................................................................................2 Item 3 – Table of Contents .......................................................................................................................................4 Item 4 – Advisory Business ......................................................................................................................................5 Item 5 – Fees and Compensation ........................................................................................................................... 17 Item 6 – Performance Fees ..................................................................................................................................... 20 Item 7 – Types of Clients ....................................................................................................................................... 20 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................................ 21 Item 9 – Disciplinary Information .......................................................................................................................... 34 Item 10 – Other Financial Industry Activities and Affiliations .............................................................................. 35 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................... 37 Item 12 – Brokerage Practices ................................................................................................................................ 38 Item 13 – Review of Accounts ............................................................................................................................... 43 Item 14 – Client Referrals and Other Compensation ............................................................................................. 45 Item 15 - Custody ................................................................................................................................................... 46 Item 16 – Investment Discretion ............................................................................................................................ 47 Item 17 – Voting Client Securities ......................................................................................................................... 48 Item 18 – Financial Information ............................................................................................................................. 49 4  Item 4 – Advisory Business Description of Firm Ely Prudent Portfolios, LLC, is a dba of the registered entity Integrated Advisors Network LLC, hereinafter collectively referred to as “the Advisor”, “Associate” or “EPP” was founded in 2007. Integrated Advisors Network, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. EPP is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Guerdon Ely is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a 5  percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is 7  compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should 9  consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third-Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial 10  practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning EPP through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. EPP may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. 13  There is an inherent conflict of interest for EPP whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. EPP or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of EPP Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. 14  Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. 15  Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. 16  Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of EPP’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management The Advisor bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in arrears. The investment management fees are negotiable at the sole discretion of the Advisor and fees for comparable services may be available from other sources. The Advisor’s fee can range from .60% to 1.0% depending upon the underlying factors of each portfolio. Investment Management Fees Incremental Account Value From Incremental Account Value To Quarter Percentage Fee Annualized Percentage Fee $ 1,000,000 0.25% $ 0.00 1.00% $ 1,000,000 $ 5,000,000 0.1500% 0.600% 0.0625% 0.250% >$ 5,000,000 ---- 17  ERISA Fee Guideline Incremental Account Value From Incremental Account Value To Quarter Percentage Fee Annualized Percentage Fee $ 1,000,000 0.3125% 1.25% $ 0.00 $ 1,000,000 $ 10,000,000 0.2500% 1.00% $ 10,000,000 $ 20,000,000 0.1875% 0.750% > $20,000,000 negotiable Financial Planning /Tangible Property Fees The Financial Planning fee will be determined based on the nature of the services being provided and the complexity of each client’s circumstances. All fees are agreed upon prior to entering into a contract with any client. As our fee is based on each client's personal situation, complexity of the service, and time commitment required, we will provide an estimate of the total fee at the start of the advisory relationship. Financial planning fees are negotiable but generally fees are charged at the rate of $200 to $300 an hour or for a fixed fee that generally ranges from $1,000 to $25,000. The Advisor may also provide general non‐ securities advice on topics that may include tax and budgetary planning, estate planning and business planning. This is considered an integral part of the financial planning process and does not generate a separate fee. On occasion, the Advisor may enter into an agreement to offer financial consultation at a similar hourly rate as the financial planning rate. Fee Billing Investment management fees will be billed quarterly in arrears. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The clients of EPP will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. 18  Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. EPP’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that EPP fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) 19  Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients Description The Adviser provides services to institutions, individuals, high net worth individuals, pension and profit- sharing plans, trusts, estates or charitable organizations, and corporations or other business entities directly. client relationships vary in scope and length of service. Account Minimums To open and maintain a portfolio management account, the Adviser generally requires that the client represents and warrants that the value of their account initially is at least $50,000. At the Adviser’s discretion, we may accept clients with smaller accounts. Pre-existing advisory clients are subject to Ely Prudent Portfolios, LLC's minimum 20  account requirements and advisory fees in effect at the time the client entered into the advisory relationship. Therefore, our Firm's minimum account requirements will differ among clients. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. 21  Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. 22  Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: 23  (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. 24  Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the 25  purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the 26  underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. 27  Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, 28  and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a 29  company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, 30  indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. 31  Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. 32  - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate 33  within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. 34  To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of EPP. Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client 35  or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Other Financial Affiliations On occasion, the Adviser (a related person) may act as a consultant to government, public and private entities concerning their pension and profit-sharing plans. In this capacity the Advisor provides general investment advice about the merits and risks of the investment alternatives available. The plan fiduciary is free to seek independent advice about the appropriateness of any investment for the plan. The Advisor acts, when hired, as a consultant to government, public, and private entities concerning their pension and profit shared plans, primarily participant education. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. 36  Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. 37  Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: 38  • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • 39  Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. 40  A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. 41  Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require 42  fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. 43  Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding 44  statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which 45  they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, 46  the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types 47  of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to 48  participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 49 

Item 1 – Cover Sheet Evoque Investments, Inc. Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 198 Main St. Suite 7 Great Barrington, MA 02130 (413) 854 - 8096 www.evoque-investments.com March 31, 2026 This brochure provides information about the qualifications and business practices of Evoque Investments, Inc. If you have any questions about the contents of this brochure, please contact us at (413) 854-8096, or by email at melissa@evoque.investments. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................4 Item 4 – Advisory Business ........................................................................................................................................5 Item 5 – Fees and Compensation .............................................................................................................................. 17 Item 6 – Performance Fees ....................................................................................................................................... 20 Item 7 – Types of Clients ......................................................................................................................................... 20 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................................. 20 Item 9 – Disciplinary Information ............................................................................................................................ 34 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................ 35 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................... 36 Item 12 – Brokerage Practices .................................................................................................................................. 38 Item 13 – Review of Accounts ................................................................................................................................. 43 Item 14 – Client Referrals and Other Compensation ............................................................................................... 44 Item 15 - Custody ..................................................................................................................................................... 46 Item 16 – Investment Discretion .............................................................................................................................. 47 Item 17 – Voting Client Securities ........................................................................................................................... 48 Item 18 – Financial Information ............................................................................................................................... 49 4  Item 4 – Advisory Business Description of Firm Evoque Investments Inc. is a dba of the registered entity Integrated Advisors Network LLC, collectively hereinafter (“the Advisor” or “Associate” or “Evoque”). Integrated Advisors Network, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. Evoque is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Melissa Mae and Jessica Bartle Investment Adviser Representatives (“IARs”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a 5  percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is 7  compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should 9  consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third party portfolio manager (the “Third Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial 10  practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Evoque through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Evoque may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. 13  There is an inherent conflict of interest for Evoque whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services Evoque or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of Evoque. Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Educational Seminars & Workshop Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third 14  party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. 15  Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. 16  Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Evoque’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management The Advisor bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. Fees are collected either in advance or in arrears. The investment management fees and collection schedule are negotiable at the sole discretion of the Advisor and fees for comparable services may be available from other sources. The investment management fees are negotiable at the sole discretion of the Advisor and fees for comparable services may be available from other sources. The fee varies from 50 basis points (.50%) up to 250 basis points (2.50%) 17  Financial Planning Services You are advised that fees for planning services are strictly for planning services. Therefore, you will pay fees and/or commissions for additional services obtained such as asset management or products purchased such as securities or insurance. Fees are negotiable. Your fees will be dependent on several factors including time spent with Evoque Investments, number of meetings, complexity of your situation, amount of research, services requested and staff resources. Financial Planning for clients, which includes complex situations, is provided under a fixed fee arrangement agreed upon at the first meeting and billed monthly. These services can be provided based on either (a) an hourly rate of up to $500/hr.; (b) a range of $500-$25,000 for one off calculations or plans, or (c) through an annual subscription to wealth management, account aggregation and financial planning for those without assets under management, billed monthly up to $500 per person in the household. These rates are increased depending on the complexity and time involved with the engagement. Certain financial plans require fifty percent of the fee payable in advance before the financial planning process is started. The remaining fifty percent is then payable at the end of the engagement. Advisor will not charge a prepayment of more than $1200 in fees more than 6 months in advance. Fee Billing Investment management fees will be billed and deducted quarterly. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The clients of Evoque will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Evoque’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Evoque fees are the lowest available for similar services. 18  Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. 19  The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients Description The Adviser provides services to individuals and high net worth individuals directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser does not have an account minimum. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the 20  basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an 21  opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) 22  Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might 23  default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates 24  decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move 25  unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the 26  investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like 27  stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private 28  placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures 29  contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a 30  predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. 31  Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. 32  - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. 33  Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. 34  Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Evoque. Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before 35  selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Evoque and associated persons do not participate in any of the above business activities. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. 36  Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. 37  Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, • • • • 38  • the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. 39  Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. 40  In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher 41  commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests 42  always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. 43  Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. 44  Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. 45  Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provide an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. 46  Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). 47  Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act 48  for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 49 

Item 1 – Cover Sheet Family First Wealth Management Firm ADV Part 2A- Firm Brochure (CRD #171991 / SEC #801-96203) 116 Ensbury Dr Little Rock, AR 72233 (501) 278-7644 john.davis@family1stwealth.com www.family1stwealth.com March 31, 2026 This brochure provides information about the qualifications and business practices of Family First Wealth Management. If you have any questions about the contents of this brochure, please contact us at (501) 278-7644, or by email at john.davis@family1stwealth.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Adviser is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................4 Item 4 – Advisory Business ........................................................................................................................................5 Item 5 – Fees and Compensation .............................................................................................................................. 17 Item 6 – Performance Fees ....................................................................................................................................... 18 Item 7 – Types of Clients ......................................................................................................................................... 20 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................................. 20 Item 9 – Disciplinary Information ............................................................................................................................ 34 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................ 34 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................... 36 Item 12 – Brokerage Practices .................................................................................................................................. 36 Item 13 – Review of Accounts ................................................................................................................................. 43 Item 14 – Client Referrals and Other Compensation ............................................................................................... 43 Item 15 - Custody ..................................................................................................................................................... 45 Item 16 – Item Discretion ......................................................................................................................................... 47 Item 17 – Voting Client Securities ........................................................................................................................... 48 Item 18 – Financial Information ............................................................................................................................... 49 4  Item 4 – Advisory Business Description of Firm Family First Wealth Management does business under the registered entity Integrated Advisors Network, LLC, collectively hereinafter “the Adviser”, “Associate” or “FFWM”. Integrated Advisors, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. FFWM is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. John Davis, Jr. is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a 5  percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is 7  compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should 9  consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third party portfolio manager (the “Third Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial 10  practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning FFWM through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. FFWM may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. 13  There is an inherent conflict of interest for FFWM whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. FFWM or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of FFWM. Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Educational Seminars & Workshop Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third 14  party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. 15  Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. 16  Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of FFWM’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management The Adviser bases its range of fees as a percentage of assets under management. Although the Investment Management Agreement is an ongoing agreement, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. The investment management fees are negotiable at the sole discretion of the Adviser and fees for comparable services may be available from other sources. The Adviser’s Fee can range from an annual percentage rate of 1% to 1.5% depending on asset level. 17  Fee Billing Fees are payable quarterly at the beginning of each calendar quarter based on the market value of the assets under management at the close of the prior quarter. Fees on additions or withdrawals are pro-rated. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. There are some legacy clients of Adviser that are invoiced and pay separately. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) The client’s custodian will deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. A client may terminate an investment advisory agreement with five (5) business days advance written notice. On termination, clients may receive a refund of advisory fees on a pro-rated basis. Adviser prefers to have management fees deducted from client accounts. There are some legacy clients of Adviser that are invoiced and pay separately. Integrated Fee Disclosure The clients of FFWM will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. FFWM’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that FFWM’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. 18  The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client 19  accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients Description The Adviser provides services to institutions, individuals, high net worth individuals, pension and profit- sharing plans, trusts, estates or charitable organizations and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser generally requires that the client represents and warrants that the value of their account initially is at least $250,000. At the Adviser’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the 20  accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to 21  the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for 22  them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. 23  Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the 24  differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. 25  Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. 26  Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another 27  benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably 28  available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. 29  Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield 30  of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. 31  Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. 32  Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using 33  AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of FFWM. 34  Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while 35  focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. FFWM and associated persons do not participate in any of the above business activities. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall 36  receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. 37  Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • 38  Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar 39  amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), 40  Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. 41  Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. 42  Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided 43  by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and 44  Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other 45  property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. 46  Item 16 – Item Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions 47  to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. 48  Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 49 

Item 1 – Cover Sheet Financial Foundations, Inc. Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 602 Center Street, Suite 105 Mt. Airy, MD 21771 (301) 829-8610 www.financialfoundationsinc.com March 31, 2026 This brochure provides information about the qualifications and business practices of Financial Foundations Inc. If you have any questions about the contents of this brochure, please contact us by telephone at (301) 829-8610, or by email at admin@financialfoundationsinc.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ................................................................................................................................... 1 Item 2 – Material Changes .......................................................................................................................... 2 Item 3 – Table of Contents .......................................................................................................................... 4 Item 4 – Advisory Business ........................................................................................................................ 5 Item 5 – Fees and Compensation .............................................................................................................. 17 Item 6 – Performance Fees ....................................................................................................................... 20 Item 7 – Types of Clients .......................................................................................................................... 20 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................. 21 Item 9 – Disciplinary Information ............................................................................................................ 21 Item 10 – Other Financial Industry Activities and Affiliations ................................................................ 35 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........... 36 Item 12 – Brokerage Practices .................................................................................................................. 38 Item 13 – Review of Accounts .................................................................................................................. 43 Item 14 – Client Referrals and Other Compensation ................................................................................ 45 Item 15 - Custody ...................................................................................................................................... 46 Item 16 – Investment Discretion ............................................................................................................... 47 Item 17 – Voting Client Securities............................................................................................................ 48 Item 18 – Financial Information ............................................................................................................... 49 4  Item 4 – Advisory Business Description of Firm Financial Foundations Inc. is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter "the Adviser", “Associate” or "Financial Foundations". Integrated Advisors Network, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC-registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. Financial Foundations is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Eric Meushaw, Mark Huber and Haywood Sarkes are Investment Adviser Representatives (“IARs”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a 5  percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is 7  compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should 9  consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial 10  practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Financial Foundations through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs Financial Foundations may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. 13  There is an inherent conflict of interest for Financial Foundations whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Financial Foundations or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of Financial Foundations. Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Educational Seminars & Workshop Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third 14  party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. 15  Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. 16  Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Financial Foundations’ Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management The Adviser bases its fees on a percentage of assets under management. Rates will be scaled to a blended rate as assets grow. Although the Investment Management Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client's discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance; therefore, at termination, any unearned fees as determined on a pro-rata basis for the portion of the quarter completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Adviser, and fees for comparable services may be available from other sources. 17  Financial Foundations client management fees range from 1.15% - 2.00%. The fee is comprised of a fee to the Adviser for its services and a fee to programs used to implement the investment strategy. Client understands and agrees that Client may incur certain charges imposed by parties other than Adviser in connection with investments made in the Account. The exact fee is based on the strategy(ies) the client and the Adviser determine best suits the client's situation. At the sole discretion of the Adviser, fees are negotiable for the different program service levels, and lower fees may be charged to clients affiliated with the Adviser. Financial Foundations Annualized Investment Management Fees Incremental Account Value From Incremental Account Value To Annual Percentage Fee $0 $499,999.99 1.15% $500,000 $999,999.99 1.00% $1,000,000 $1,999,999.99 0.90% $2,000,000 $2,999,999.99 0.80% $3,000,000 $3,999,999.99 0.70% $4,000,000 and above 0.50% Financial Planning A fee for a financial plan is not charged at this time. Fee Billing Investment management fees are billed quarterly, in advance, meaning that we invoice you before the three- month billing period has begun. Payment in full is expected upon invoice presentation. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Fees for financial plans are not charged at this time. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. 18  Integrated Fee Disclosure The clients of Financial Foundations will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Financial Foundations’ fees may be higher or lower than other advisory groups at Integrated and there is no representation that Financial Foundations fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. 19  Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients Description The Adviser generally provides investment advice to individuals, high net worth individuals, pension and profit- sharing plans, trusts, estates, or charitable organizations, and corporations or business entities. Client relationships 20  vary in scope and length of service. Other advisory groups of Integrated provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Advisor generally requires that the client represents and warrants that the value of their account initially is at least $500,000. At the Adviser's discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to 21  measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. 22  When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. 23  The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for 24  receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. 25  Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund 26  will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected 27  project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. 28  Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. 29  Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. 30  Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a 31  warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. 32  - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or 33  investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. 34  To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Financial Foundations. Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. 35  Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. Registered Representative of Broker-Dealer Integrated is not registered and does not intend to register as a broker-dealer. Still, in connection with their approved outside business activities, some Associates are Registered Representatives (“RRs”) of non-affiliated broker- dealers, Members of FINRA/SIPC. Associates with these unaffiliated broker-dealers can provide brokerage services as an RR of the unaffiliated broker-dealer firm. When acting in the capacity of an RR, the Associates will sell, for commissions, general securities products and will receive commission-based compensation in connection with the purchase and sale of such securities, including 12b-1 fees for the sale of investment company products. If your Adviser Representative offers brokerage products as an RR through their unaffiliated broker-dealer, they are not acting in a brokerage capacity or on behalf of Integrated concerning the services provided under our Agreement(s). Integrated is not involved in the transaction and receives no compensation for the Associate's outside business activity. Associates who provide brokerage services through unaffiliated broker-dealers are independent contractors of such companies. Any compensation earned by these individuals in their capacities as RRs is separate, in addition to, and not related to our advisory fees or Agreement to provide advisory services. Clients are under no obligation to use the firm's Associates’ services in this different capacity as broker-dealer employees. Insurance Services Financial Foundations and/or certain associated persons of Financial Foundations may sell insurance products to advisory clients. Some Associates are licensed as independent insurance agents through non-affiliated insurance companies offering fixed, fixed index, variable annuities, life, or long-term care universal life or other insurance products, and insurance services clients may decide to use Integrated for financial planning or investment advisory services. In these capacities, Integrated Adviser Representatives can recommend to firm clients and receive separate, yet customary, commission compensation, including bonuses and trail commissions, resulting from the purchases and sales of these products from the insurance agencies with whom they are presently or with whom they may become appointed in the future in addition to their compensation from Integrated. Such commissions and advisory fees are separate from the firm's advisory fees and Agreements, and clients are under no obligation, contractually or otherwise, to purchase insurance products or receive investment advice through insurance-licensed Associates in their capacities as insurance agents and/or Integrated Adviser Representatives. 36  Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. 37  As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are 38  required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: 39  Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate 40  securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we 41  could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. 42  Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political 43  events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. 44  Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be 45  delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. 46  Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provide an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile 47  and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their 48  right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. 49  Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 50 

Item 1: Cover Page ________________________________________________________________________________________________ Integrated Advisors Network, LLC Form ADV Part 2A - Firm Brochure (CRD #171991 / SEC #801-9620) 8117 Preston Road Suite 300 Dallas TX 75225 Telephone: 855.729.4222 Fax: 310.742.0227 www.integratedadvisorsnetwork.com www.linkedin.com/company/integrated-advisors-network/mycompany March 31, 2026 This Brochure provides information about the qualifications and business practices of Integrated Advisors Network, LLC, an investment advisory firm registered with the U.S. Securities and Exchange Commission. If you have any questions about the contents of this Brochure, please contact us at 855.729.4222 or at compliance@integrate dadvisorsnetwork.com. The information in this Brochure has not been approved or verified by the U.S. Securities and Exchange Commission or any state securities authority. Nothing in this document is to be construed as a recommendation or an endorsement by the SEC or any state securities authority or an offer of securities; please refer to the actual investment offering and related legal documentation for complete disclosures. Registration does not imply a certain level of skill or training. Investments involve risk, including the possible loss of principal. An adviser's written and oral communications provide information to determine whether to retain their services. This Brochure is on file with the appropriate regulatory authorities, as federal and state regulations require. Additional information about Integrated Advisors Network, LLC is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. (Click on the link, select "Investment Adviser- Firm," and type in the firm name or CRD # 171991. Results will provide you with all the Integrated disclosure brochures.) 1  Item 2: Material Changes ________________________________________________________________________________________________ In this item, Integrated Advisors Network, LLC ("Integrated" or "the Adviser") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost- effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. 2  You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3: Table of Contents ________________________________________________________________________________________________ Item 1: Cover Page .................................................................................................................................. 1 Item 2: Material Changes ......................................................................................................................... 2 Item 3: Table of Contents ........................................................................................................................ 4 Item 4: Advisory Business ....................................................................................................................... 5 Item 5: Fees & Compensation ................................................................................................................ 17 Item 6: Performance-Based Fees & Side-by-Side Management .............................................................. 22 Item 7: Types of Clients ........................................................................................................................ 22 Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ....................................................... 23 Item 9: Disciplinary Information ............................................................................................................ 34 Item 10: Other Financial Industry Activities & Affiliations .................................................................... 35 Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ................. 37 Item 12: Brokerage Practices ................................................................................................................. 39 Item 13: Review of Accounts................................................................................................................. 43 Item 14: Client Referrals & Other Compensation ................................................................................... 44 Item 15: Custody ................................................................................................................................... 45 Item 16: Investment Discretion .............................................................................................................. 46 Item 17: Voting Client Securities ........................................................................................................... 47 Item 18: Financial Information .............................................................................................................. 48 Item 19: Additional Information ............................................................................................................ 48 4  Item 4: Advisory Business ________________________________________________________________________________________________ Description of Firm Integrated Advisors Network, LLC is an investment advisor registered with the U.S. Securities and Exchange Commission ("SEC") pursuant to the Investment Advisers Act of 1940 (the "Advisers Act"), as amended. The firm, located at 8117 Preston Road, Suite 300, Dallas, TX 75225, and organized as a Limited Liability Company in the state of Delaware in 2014, has been SEC-registered since May 11, 2015. Integrated’s Principal Owner is TX-HI, LLC. Jeffrey J. Groves, Co-Founder, Linda M. Pix, Co-Founder & Chief Relationship Officer, and Michael A. Young, President & Managing Partner, are control persons. (Please refer to Michael Young’s individual Form ADV Part 2B brochure supplement for additional details on their formal education and business background.) As used in this brochure, the words "we," "our," "us," or “the Firm” refer to Integrated Advisors Network, LLC ("Integrated," " or “the Adviser”) and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. The term Associated Persons (or "Associates") refers to Integrated’s Covered Persons and Supervised Personnel, the officers, employees, and individuals providing investment advice or advisory services on behalf of the firm. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Advisor Representatives (“Advisor Representatives”). One or more Advisor Representatives manage each advisory relationship at Integrated, who are registered with the firm and serve as the primary point of contact between Integrated and the client. Advisor Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Advisor Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Advisor Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Advisor Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Advisor Representative or Integrated’s Chief Compliance Officer (“CCO”) directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. "Co-Branding" Disclosures Integrated offers services through its network of Advisor Representatives. Some Advisor Representatives have other business interests, as described in their Form ADV disclosure brochures, and may have established their own legal business entities to conduct their advisory practices (a "doing business as" or "DBA" firm), whose trade names and logos are used for marketing purposes and may appear on their brochures, marketing materials or client statements. Clients should understand that any DBA entities referenced by Advisor Representatives are their own separate legal entities and are not subsidiaries or affiliates of Integrated Advisors Network, LLC, the investment adviser registered with the U.S. Securities and Exchange Commission. Integrated supervises DBA-related materials, and all investment advisory and financial planning services offered through these Advisor Representatives are provided through Integrated. Advisor Representatives may, at their discretion, offer proprietary strategies or products that are not reviewed or approved by Integrated’s investment or compliance personnel. 5  While Advisor Representatives operate under the supervision of Integrated, each DBA entity is independently owned and managed. Business models, services, and offerings may vary among DBA entities. Protections, terms, and conditions applicable when engaging with one DBA entity may not apply when engaging with another. Clients should carefully review the specific services and disclosures provided by the Advisor Representative and DBA entity with which they choose to engage. When engaging in the services of one DBA entity’s advisory practice, clients are not affected by the fees, practices, or activities of another. The services provided by one regulated entity will only be provided concerning that entity and are not for services provided by another. Further, the fees of one advisory practice group may be higher or lower than those of another. Integrated does not make any representation that any fees, products, services, or those of any referred third party are offered at the lowest available cost for similar services; clients may be able to obtain the same at a lower price from other providers. Integrated advisory clients should also be aware that any other business lines offered by DBA entity professionals, such as brokerage and insurance products and services, may be provided through unaffiliated or affiliated firms and are separate and distinct from the advisory services provided through Integrated. Other business lines offered are (1) unrelated to the client's relationship and agreements with Integrated, (2) not part of Integrated's advisory or management services, and (3) subject to separate contractual arrangements. Further, the protections afforded to a client under applicable investment advisory laws and regulations generally do not apply to those provided by any non-advisory contract. For specific details, clients and prospective clients are encouraged to carefully refer to each advisory group's disclosure brochures and ask their Advisor Representative questions about any item they may be unclear about or desire additional information. (See Item 10 - Other Financial Industry Activities & Affiliations for additional disclosures regarding Associate outside business activities.) As of the date of this Brochure, the following (co-branded/DBA) independent businesses and their registered investment professionals offer their advisory services through Integrated: • Abundantia Capital Corporation • All Source Investment Management • Andersen Capital Management, LLC • Archer Bay Capital • Auctum Wealth Management. LLC • B&B Strategic Management, LLC • Burns - Blackburn Group • Candid Financial • Capital City Financial Partners • Copper Crest Capital • Echelon Investment Management • Ely Prudent Portfolios, LLC • Evoque Investments, Inc. • Family First Wealth Management • Financial Foundations, Inc. • JC Investment Management • Lattice Wealth Management Group, Inc. • Lienart Family Asset Management • Long Course Capital, LLC • Longview Investment Advisors • Menlo Oaks Capital Group • Militello Wealth Management • Miller Pacific Financial Advisors • Mosaic Financial Solutions • Nspire Wealth • Open Network Financial Consulting • Rama Financial, LLC • SF-IAN • Sand Creek Investment Partners, Inc. • Sawyer Capital Investment Advisors • Select Wealth Advisers • Shields Capital • Sztrom Wealth Management, LLC • Vineyard Asset Management, LLC • Vineyard Global Advisors • Vineyard Wealth Advisors • Yorkshire Wealth Management • Zimmerman Wealth Advisory Group, LLC Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s investment professionals emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. Clients may choose from the following specific services: Investment Management & Supervisory Services, including: • - ERISA - Retirement & Employee Benefit Plan Services - Managed Account Solutions (“MAS”) Program Services • Financial Planning Services • Hourly & Fixed Fee Consulting Services • Educational Seminars & Workshops Services 6  Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Advisor Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, Integrated may recommend the services of other professionals for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as- needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement between the client and their selected referred professional(s). Integrated is not a party to the transaction and does not maintain the authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities Integrated's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Advisor Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation - Integrated will not be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify Integrated in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. Integrated reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, to provide proper financial advice. The following is a summary description of the specific advisory services covered by this Brochure and the nature of the services. Please consult the applicable client Agreement and fee schedules for additional information regarding each service. Investment Management & Supervisory Services Investment management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 7  If appropriate for the account type established, Integrated will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of clients funds or securities. Integrated primarily recommends that its clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Integrated will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement and IPS. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Advisor Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income and Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: - Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. - Follow policies and procedures designed to ensure that we provide advice that is in your best interest. 8  - Charge no more than is reasonable for our services. - Give you basic information about conflicts of interest. Integrated benefits financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with our Firm. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Integrated, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: - Employer retirement plans generally have a more limited investment menu than IRAs, and - Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. 2. Consider plan fees - your current plan may have lower fees than Integrated's fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. - You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. Integrated's strategy may have a higher risk than your plan's option(s). 3. 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher 9  9. education expenses, or a home purchase. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that Integrated has no responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Advisor Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Integrated is not responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Integrated's Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third-Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Advisor Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. 10  According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred-manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and 11  asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. The Programs Integrated will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third-party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment 12  profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategis UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated can allocate assets among private funds, including funds of funds, managed by third parties. With respect to fund of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Integrated does not invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Services Integrated offers broad-based personal financial planning services tailored to the client's needs and differentiated by the scope and depth of the areas to be addressed, analysis complexity, recommendations developed, deliverables created, and presentation. The scope of services is determined between the client and Advisor Representative. Financial planning services can take the form of one-on-one advice on investment matters or other guidance as contracted by the client and will range from comprehensive financial planning to consulting on a particular issue, including a focus on topics such as lifestyle objectives, retirement planning, planning for major purchases, long-term care needs, estate planning issues or other financial planning or consulting services needs as designated. A financial plan may include but is not limited to a net worth statement, cash flow statement, review of investment accounts - including reviewing asset allocation and providing repositioning recommendations, strategic tax planning, a review of retirement accounts and plans - including recommendations, insurance policy analysis and recommendations for changes, if necessary, one or more retirement scenarios, estate planning evaluation and recommendations, and education planning with funding guidance. Clients will execute a Financial Planning Agreement setting forth the terms and conditions of the engagement, including termination, describing the services' scope and the fixed or hourly fees due before Integrated commences services. The final fee structure will be documented within the executed Agreement. 13  Depending on the scope of the assignment and the complexity of the planning to be performed or advice to be given, financial planning services typically take approximately one week to two months. Financial plans are based on the client's financial situation when the plan is presented and the financial information disclosed by the client to Integrated. Since financial planning is a discovery process, situations occur wherein the client is unaware of specific financial exposures or predicaments. If the client's case differs substantially from what was disclosed at the initial meeting, a revised fee will be provided for review and acceptance. When a fee increase is necessary, the client must approve and agree to the scope change before any additional work is performed. In such cases, we will notify the client to obtain this approval. (See Item 5: Fees & Compensation for further details.) As with all Integrated advisory services, the expectation is that the client will promptly notify the Adviser in writing of any material changes in assets, net worth, indebtedness, or planning objectives that the Adviser would not otherwise know. The client or their successor shall also promptly notify Integrated in writing of (a) the dissolution, termination, merger, or bankruptcy of the client if the client is other than a natural person and (b) the occurrence of any other event which might affect the validity of their Financial Planning Agreement or Integrated's authority thereunder. Financial planning engagements terminate upon delivery of the written plan. Additional reviews may be conducted upon request, and written updates to the financial plan may be provided in conjunction with the review. Updates to financial plans may be subject to our then-current hourly rate, which the client must approve in writing and before the update. Financial planning services may be the only service provided to the client. Executing a Financial Planning Agreement neither constitutes an agreement for nor requires that the client use or purchase investment advisory or other services offered by Integrated, or any insurance or other products or services provided by any advisory Associate as a result of any business activities in which they may participate outside their advisory activities with the Adviser. Neither Integrated nor the Advisor Representative will have discretionary investment authority when offering financial planning or consulting services. The services do not include implementing or monitoring the Advisor Representative's recommendations to the client. If the client receives a written financial plan, the plan will not include information or analysis concerning liability risks, tax planning, or tax preparation services. If such services are necessary, the client shall be responsible for obtaining them from one or more third parties. Integrated reserves the right to terminate any financial planning engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in its judgment, to provide proper financial advice. Clients should consult their Financial Planning Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Hourly & Fixed Fee Consulting Services Integrated provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Integrated may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Advisor Representative and placing any resulting transactions. After engagement completion, Integrated and the Advisor Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) 14  Educational Seminars & Workshops Services Integrated provides complimentary investment educational seminars and workshops services on various investment topics, " as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendees' needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Advisor Representatives will not provide personalized investment advice to attendees during such events. Integrated provides investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. Conflicts of Interest Please note that Integrated has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser or its Advisor Representatives an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to effect the transaction through Integrated, its Advisor Representatives, Associates, or any other third party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in the Adviser's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Integrated will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Integrated provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated avoids market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Integrated reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. 15  As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. Integrated avoids market timing but will increase cash holdings when necessary. (Please note that an investment in money market funds is not insured or guaranteed by the FDIC or other government agency.) Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Integrated will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. In no event and regardless of the advisory service provided, the Adviser is obligated to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client-imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. Wrap Fee Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. 16  Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. Bundled Fee Arrangement Certain independent investment professionals (DBA entities) affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Assets Under Management As of December 31, 2025, the Adviser's assets under management total are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation ________________________________________________________________________________________________ Integrated’s advisory clients agree to pay an asset-based advisory fee calculated according to the indicated fee schedules. Under the Advisers Act Rule 204‑3 (the “Brochure Rule”), investment advisers must provide clients with a written disclosure statement. A copy of the Form ADV Part 2A Brochure and the applicable Advisor Representative’s Part 2B Brochure Supplement before or at the time the client enters into an Investment Management Agreement. Advisers providing impersonal investment advice for which the client pays less than $500 per year are not subject to the Brochure Rule. If these disclosure documents are provided at or after the time of Agreement execution, clients have the right to terminate the Agreement without penalty within five (5) business days after execution. Advisory Services Fees This section explains how Integrated is compensated for advisory services. Specific fee schedules and billing arrangements for each service are detailed in subsequent sections, in each client’s written Agreement, and in the applicable practice group’s disclosure brochure. Investment Management Fees - Depending on the practice group, fees may be billed monthly or quarterly, in advance or arrears, and calculated using quarter-end, month-end, or average daily balance, as specified in the client Agreement. Financial Planning & Consulting Fees - These may be charged as hourly, fixed, or subscription fees and billed in advance, arrears, or a combination (e.g., 50% upfront, remainder at completion). Some practice groups include financial planning at no additional cost for investment management clients, while others charge a separate fee. 17  Bundled Fee Arrangements - Certain practice groups offer bundled fee structures that combine advisory services with other costs. Details on included services, excluded costs, and applicable schedules are provided in the relevant Form ADV Part 2A Brochure. Variability by Practice Group - Fee schedules, minimums, and billing practices differ by practice group and are fully disclosed in each client’s Agreement and the applicable brochure. This summary provides a general framework for understanding Integrated’s compensation practices. Please refer to the detailed descriptions that follow, and to each practice group’s disclosure brochure, for specific information regarding each advisory service. Fee Negotiation Availability Under certain circumstances, advisory service fees are negotiable up to the maximum annual rates listed herein, subject to limitations and approval by Integrated. Practice groups may, at their discretion, offer negotiable minimums or waive fees. This means a DBA Advisor Representative may reduce or waive minimum fees based on specific factors such as an existing financial planning relationship, anticipated future earning capacity, expected additional assets, total assets under management, related accounts, account composition, client negotiations, or pro bono considerations. At Integrated’s discretion, certain family or related accounts may be assessed fees based on the combined balance of all accounts. Integrated will only accept clients below the stated minimum portfolio size if, in the Adviser’s judgment, the smaller portfolio will not result in a substantial increase in investment risk beyond the client’s identified risk tolerance. Final fee structures for selected advisory services will be reflected in each client’s written Agreement. Integrated believes its fees are competitive with similar programs offered by other firms; however, lower fees for comparable services may be available elsewhere. While Integrated seeks to provide advantageous arrangements, negotiable fees mean some clients may pay higher or lower fees than others for similar services, depending on factors such as total assets, number of related accounts, inception date, or other considerations. Clients are responsible for any tax liabilities arising from transactions. Integrated and its practice groups do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Investment Management & Supervisory Services Integrated provides investment management and supervisory services on a fee-only basis based on the value of the assets to be managed, the work to be provided, and the complexity of their situation. Investment management and supervisory services typically require a minimum portfolio value of $50,000. However, the Adviser reserves the right to accept accounts below this minimum based on the client’s individual circumstances If engaged, Integrated will charge an annual fee of up to 2.95%, based upon a percentage of the market value of the client’s assets under management, calculated and billed consistent with the Adviser’s disclosure documents and each client’s contracts’ compensation arrangements. Individual client account fees will vary depending on the selected Program’s investment options and the fee schedule of each Integrated advisory group’s practices. However, in all cases, the Advisor Representative's advisory practices must ensure that the advisory fees they assess clients are accurate, up-to-date, and aligned with Integrated’s disclosures, up to the maximum annual rates listed herein. Clients should refer to the individual brochure of each advisory group for specific details. (Note: Lower fees for comparable services can sometimes be available from other sources.) Each client's executed Agreement will indicate the final advisory fees and fee-payment arrangements before the delivery of any advisory services. Fee Billing & Payment Integrated’s annual investment management and supervisory services fees are prorated, billed monthly or quarterly, and payable in advance or arrears according to the client’s Agreement, based on a percentage of assets under management as of the last day of the preceding quarter. The first quarter’s fees shall be calculated on a pro-rata basis. Clients will choose how they wish to be billed and indicate their fee billing and payment preference on their advisory services Agreement. Clients may have their fees directly debited from the account held at their custodian of record or billed. Integrated will not access client funds for fees without written client consent. 18  Clients who wish to have their fees directly debited will authorize Integrated in writing to deduct any advisory fees due from their custodial account directly and provide their custodian with authorization to deduct such amounts when due and remit them straight to Integrated. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing, a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Clients who wish to be billed by Integrated for their advisory services fees will authorize this form of payment in writing on their advisory Agreement and request that Integrated invoice them directly monthly or quarterly for any fees due. Clients will then make fee payments to Integrated by separate check or credit card within 45 days of invoice receipt. Under no circumstances will any Integrated advisory fees be deducted from amounts they hold within their custodial account(s). (See Item: 15: Custody for additional details.) Additions, Withdrawals & Terminations Additions, withdrawals, and terminations to investment management and supervisory services client accounts are governed by the Agreement that the client signs directly with Integrated. Clients may make cash or securities additions to their accounts at any time. Integrated reserves the right to liquidate any transferred securities or decline to accept particular securities into the client's account. If Integrated liquidates transferred securities, clients may be subject to additional fees such as transaction fees, other fees assessed at the mutual funds level, such as contingent deferred sales charges, and tax ramifications. Clients may withdraw from their accounts at any time in cash or securities. Withdrawals are subject to the usual and customary securities settlement procedures. Additionally, if the client transfers their account to another firm, they may pay an outgoing account transfer fee. Terminations can be made to Integrated Agreements by written notice without penalty within five (5) business days after the Agreement execution date. After that, the contracts between Integrated and the client will continue according to the Agreement’s provisions, which state either party may terminate the Agreement without penalty upon 30 days written notice to the other party, following the Agreement’s provisions. (A "business day" shall be any day when the New York Stock Exchange is open for trading.) Terminations become effective on receipt of such notice and will not affect: • The validity of any action previously taken by the Adviser under the Agreement. • Liabilities or obligations of the parties from transactions initiated before termination of the Agreement. • The client's responsibility to pay management and other fees due, pro-rated through the termination date. The annual services fee will be pro-rated through the termination date. At termination, after the prior full billing period, the portfolio value will be used as the basis for the fee computation, adjusted for the number of days during the billing period before termination. Based on the termination date, any prepaid, unearned fees will be promptly refunded to the client on this pro-rata basis. If the client is a natural person, the client's death, disability, or incompetency will not terminate or change the terms of an Agreement. However, the client's executor, guardian, attorney-in-fact, or another authorized representative may terminate the client's Agreement by providing written notice to Integrated. Before termination, all directions given or actions taken or omitted by Integrated before the effective Agreement termination shall be binding upon the client and any successor or legal representative. 19  Upon the termination of an Agreement, Integrated will not possess any obligation to recommend or take any action with regard to the securities, cash, or other investments in a client's account and will no longer be entitled to receive fees from the termination date. Clients should refer to their Investment Management Agreement for complete details. ERISA - Retirement & Employee Benefit Plan Services ERISA - retirement and employee benefit plan services fees are billed and payable according to the preceding investment management and supervisory services schedules. Account additions, withdrawals and terminations also follow the same procedures. Clients should refer to their Agreement for complete details. Managed Account Solutions (“MAS”) Program Services In addition to the Adviser’s advisory fee, clients participating in MAS Programs pay separate fees charged by unaffiliated third parties, which may include: an investment management fee charged by the selected Third‑Party Manager; and an overlay, platform, or administrative fee charged by Envestnet. • • These fees are assessed and deducted separately pursuant to the applicable Envestnet and other Third‑Party Manager program agreements and are in addition to the Adviser’s advisory fee. Because multiple fee components apply, the total cost of participating in an Envestnet Program and Third-Party Managers may be higher than other advisory arrangements. Clients should carefully review all applicable Envestnet and Third‑Party Manager disclosures for a complete description of fees and expenses. Based upon a percentage of the market value of the client’s assets under management, fees calculated and billed consistent with the Adviser’s disclosure documents and each client’s contracts’ compensation arrangements will not exceed 2.95%. Fee Billing & Payment According to the Managed Account Solutions (“MAS”) Program services Program Agreement, clients enter with the referred manager; fees are billed and payable quarterly in advance or arrears. At the account's inception(s), the first pay period's fees will be calculated pro rata. Integrated does not participate in the referred manager’s advisory fee calculation. Final fee structures will be designated within the client’s executed Program Agreement, with fee billing/payment following the Program Agreement’s terms. TPM Program clients should review all applicable disclosure brochures before participating in any TPM Program. It is important to note that the client's referred managers can charge fees in addition to the above fee schedule and will typically reserve the right to reduce or waive the fee at their sole discretion. Added fees and expenses can be charged by investments in the portfolio's model(s). Such fees will be paid out of the client's account assets and are in addition to the fees clients pay to Integrated and any third-party referred managers. Integrated does not receive any portion of the separate commission fees or costs associated with Program client accounts. As the services from Integrated and the Program are available through other companies at differing prices, Integrated encourages the client to review the components that determine charges and service calculations. Factors for consideration should include, but are not limited to, account size, type(s) of account(s), transaction charges, the range of advisory services, and each service's ancillary charges. Integrated urges Program clients to discuss any questions or concerns with their Advisor Representative and the referred manager. Additions, Withdrawals & Terminations Additions, withdrawals, and terminations to Managed Account Solutions (“MAS”) Program services client accounts will also be governed by the separate Program Agreement that the client signs directly with the referred manager. Program Agreements will continue until the client or third-party manager terminates the relationship by written notice to the other. The TPM is responsible for refunding unearned Program fees per the Program Agreement's terms. If the total value of the client's account or aggregated accounts falls below the TPM’s minimum account size for a withdrawal or other reason, the TPM may terminate its Program Agreement. Before participating in any referred manager Program, clients should review all applicable disclosure brochures, investor profiles, and TPM Program Agreements for complete details. 20  Financial Planning Services Fees Financial planning services fees are predicated upon the facts known at the start of the engagement. The minimum annual flat-rate fee for financial planning is $500 (or $125 each quarter if paid four times a year vs. annually). Based on the client's services, fees can range higher to engage with Integrated as defined in each client's written and executed Financial Planning Agreement. At Integrated's discretion, limited services are offered at a discounted rate. Since financial planning is a discovery process, situations occur wherein the client is unaware of specific financial exposures or predicaments. If the client's situation differs substantially from what was disclosed at the initial meeting, a revised fee will be provided for a mutual agreement. Agreements may be amended only by the client and Integrated's mutual written consent. Ultimately, fees will be determined at the discretion of the Advisor Representative assigned to the account based on the required resources and plan complexity. If a financial planning services fee increase is necessary, the client must approve the scope change before any additional work is performed. Financial planning fees are billed in advance when the Financial Planning Agreement is executed and are payable within ten (10) days of invoice presentation. Clients may directly authorize deducting these fees from their custodial account or pay them via check or credit card. After plan delivery, future face-to-face meetings and follow-up implementation work may be scheduled as necessary, free of charge for up to 3 months. The client will receive a fee refund upon delivery of the completed financial plan if applicable. Alternatively, Integrated may require the client to pay an initial retainer of 50% of the estimated financial planning fee before any services are rendered. The remaining balance is payable upon completion of the contracted services. Integrated is not responsible for any additional fees, commissions, expenses, or charges related to the transfer of assets from any other investment manager or advisor, real estate transactions or other expenses associated with real property transactions, or fees related to any major purchases or other transactions the client effects. The client's responsibility is to remit payment for the administrative expenses and fees due to the TPMs by Integrated for the financial plan and to timely resolve such additional fees, commissions, expenses, or charges. Hourly & Fixed Fee Consulting Services Fees Hourly and fixed fee consulting services are provided for either a flat, fixed fee computed on a project basis or a (negotiable) hourly fee of $500, as defined in each client's written contract. Fees are paid in arrears, due upon completion of the consulting service and can be paid by direct debit from the account held at their custodian of record or billed and paid by check within fifteen (15) days of invoice receipt. Clients should refer to their Agreement for more details. If a fixed-fee project terminates before project completion, Integrated will determine the project's percentage based on the hourly rate and the number of hours already expended. If less than one-half of the project is finished, a refund will be made for any unearned fees. If more than one-half of the project is complete, the client will be invoiced for the additional time expended over fees already paid. Integrated will invoice the client for any work finalized through the termination date if an hourly agreement is terminated before completing the agreed-upon services. Clients should refer to their Consulting Services Agreement for more details. Educational Seminars & Workshop Fees Educational seminars and workshops are provided free of charge. Conflicts of Interest Please note that most Integrated advisory clients will pay a fee based on a percentage of the assets under advisement. This compensation method can sometimes lead to conflicts of interest between our firm and the client regarding our advice. As the services available from Integrated can be found through other companies at differing prices, we recommend that clients review the components that determine charges and service calculations. Factors for consideration should include, but are not limited to, account size, type(s) of account(s), transaction charges, the range of advisory services, and each service's ancillary charges. Integrated urges clients to discuss any questions or concerns with their Advisor Representative. Other Fees & Expenses Clients should understand that Integrated’s advisory fees are exclusive of bank or custodial fees, brokerage commissions, transaction charges, and other related costs and expenses that may be incurred. Examples include custodial fees, odd-lot differentials, fixed income trading charges, mark-ups and mark-downs, commissions, dealer spreads, and wire transfer 21  or electronic fund fees. Charges may also be imposed directly by exchange-traded funds (“ETFs”), mutual funds, or other managed products, as disclosed in each fund’s prospectus. These may include 12b-1 fees, short-term redemption fees, and other annual expenses. Third-party service providers may impose additional fees for services elected by clients, such as certificate delivery, American Depositary Receipts (ADRs), and transfer taxes mandated by law. Portfolios that include foreign securities may incur costs related to execution on foreign exchanges. Clients should also note that mutual funds and ETFs pay advisory fees to their managers, which all shareholders indirectly bear. As a result, clients with these products in their portfolios effectively pay fees to Integrated, the custodian, and the fund manager. Integrated’s fees are separate from those charged by mutual funds or other investment products, and each fund’s prospectus fully describes these costs. Because clients could invest directly in mutual funds or partnerships without engaging Integrated, they should evaluate both the program fee charged by Integrated and the underlying fund expenses to understand the total cost of services. Integrated does not accept commission-based compensation or receive mutual fund 12b-1 fees. Clients may also incur account termination fees when transferring accounts between custodians or broker-dealers. These fees vary widely—from nominal amounts to several hundred dollars or more. Clients should contact their custodian for details. (See Item 12 – Brokerage Practices for additional information.) Integrated believes its fees are competitive with similar programs offered by other firms; however, lower fees for comparable services may be available elsewhere. While clients could invest directly in certain funds, doing so would not include the services provided by Integrated—such as assistance in selecting appropriate investments, disciplined portfolio rebalancing with tax considerations, and guidance to avoid emotional reactions to short-term market events—unless they engage another adviser or provider offering comparable services. Additionally, some funds may only be accessible through an investment adviser. Integrated encourages clients to speak directly with their Advisor Representative regarding any questions about fees and compensation. Item 6: Performance-Based Fees & Side-by-Side Management ________________________________________________________________________________________________ Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance-based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Integrated charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain Supervised Persons may, through separate DBA entities, offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Advisor Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Clients should review the applicable DBA entity’s disclosure brochure and any offering documents for details regarding performance-based fee arrangements and associated risks. Item 7: Types of Clients ________________________________________________________________________________________________ Client Types Integrated typically provides discretionary and non-discretionary investment advice and management supervisory services to high-net-worth individuals, trusts, estates, charitable organizations, pension & profit-sharing plans, corporations and business entities. Client relationships vary in scope and length of service. 22  Minimum Account Size Investment management and supervisory services and ERISA - retirement and employee benefit plan service clients typically require a minimum account size of $50,000. Integrated and its practice groups may, at their discretion, waive or reduce minimums or charge a lesser management fee based upon specific criteria such as a pre-existing financial planning client, anticipated future earning capacity, expected future additional assets, the dollar amount of assets to be managed, related accounts, account composition, negotiations with the client, and pro bono activities, among others. Smaller portfolio accounts will only be accepted if, in the sole opinion of Integrated, the lesser account size will not cause a substantial increase in investment risk beyond the client's identified risk tolerance. The portfolios of family members may also be aggregated to meet minimum account requirements. (See Item 5 - Fees & Compensation, Fee Negotiation Availability for additional details.) The minimum account size required by third-party managers under Integrated’s Managed Account (“MAS”) Program services may be higher than Integrated’s, as disclosed in each TPM’s Program Agreement. (Note: In selecting a referred manager, the client is responsible for understanding the account minimums, requirements, and fee agreement they are executing with the referred manager.) Clients do not require account establishment or minimums to participate in hourly fixed-fee and financial planning consulting services. Item 8: Methods of Analysis, Investment Strategies & Risk of Loss – update based in iar adv ________________________________________________________________________________________________ Methods of Analysis Integrated provides customized investment recommendations based on each client’s specific circumstances and stated investment objectives. Information supplied by the client forms the basis for developing a strategic asset allocation plan designed to help achieve both short- and long-term financial goals. Portfolio advice considers factors such as income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences. Reviews can also address cash flow and liquidity requirements, tax considerations, estate planning, risk management, and other elements significant to the client’s financial situation. Existing investments are typically evaluated to determine whether they align with the client’s objectives. Integrated relies on the accuracy of information provided by clients or their professional advisors and does not independently verify such data unless otherwise agreed. Investment Strategies We use one or more of the following methods of analysis or investment strategies when providing investment advice to you: Charting Analysis - Involves the gathering and processing of price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - A technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore, the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - An additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the 23  environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - Involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Inverse ETF – Inverse ETFs are investment products designed to provide returns that are the opposite of the performance of a stated market index or benchmark on a daily basis. Advisers may use ETFs on a limited, short- term, or tactical basis to manage market exposure or express short-term market views. Risk: Inverse ETFs reset daily and are subject to compounding effects, which may cause performance over periods longer than one trading day to differ materially from the inverse of the performance of the underlying index. These investments involve heightened risk, including increased volatility, tracking error, and the potential for rapid or significant losses, and are generally not appropriate for long‑term investment strategies. Long-Term Purchases - Securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy assumes that the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time, even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently, minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Pooled Investment Vehicles and Alternative Allocations – In connection with client portfolios that obtain exposure to alternative investments through pooled investment vehicles, the Adviser relies on investment selection, allocation methodologies, and portfolio construction processes implemented at the fund level by the applicable fund sponsor or manager, which may include the use of proprietary or third-party models. The Adviser does not independently construct, control, or replicate such models and does not manage the day-to-day investment decisions of the pooled investment vehicle. As a result, the Adviser’s ability to influence investment outcomes within these vehicles is limited, and performance is dependent on the methodologies, assumptions, and risk management practices employed by the fund sponsor or manager. Risk: Investments in pooled investment vehicles that utilize proprietary or third-party models involve additional risks, including the risk that model assumptions, data inputs, or methodologies may be incorrect, incomplete, or fail to account for changing market conditions. Because the Adviser does not control or independently validate such models and has limited influence over fund-level investment decisions, clients may experience significant losses, limited liquidity, or outcomes that differ materially from expectations based on traditional asset allocation or risk management approaches. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term 24  interest rate changes, cyclical earnings announcements, etc.), but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid substantial losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Advisor Representatives may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Advisor Representatives will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client. It may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: Note: Items are presented alphabetically for ease of reading, not in order of importance. 25  Adviser's Investment Activities - The Adviser's investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Artificial Intelligence Risk - We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. Further, additional risks may also be disclosed for different firm advisory groups. Bank Obligations - Including bonds and certificates of deposit, may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or changes in banking regulations. Bonds - Corporate debt securities (or "bonds") are typically safer investments than equity securities. Still, their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default, when the bond is set to mature, and whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds – Bond funds have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - The risks associated with a specific industry or company. Certificates of Deposit - Certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - The securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - Advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of the firm and its Associates. Corporate Bonds - Corporate bonds are debt securities that are used to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at 26  maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - Credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - Overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk – A portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk – Generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease in value; the investment may incur a loss. Financial Risk - Is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - Agency, corporate and municipal bonds and all mortgage-backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - From time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, and enforcing legal rights in some foreign countries is difficult, costly, and slow. There are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - Investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline, but establishes other positions designed to gain from those 27  same developments, thus moderating the portfolio positions' decline in value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates, which may cause the value of many fixed-income investments to decline. Lack of Registration Risk - Funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - Leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or using different leveraging strategies. Limited Partnerships Risk - A limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - The risk of being unable to sell an investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - Long-term trading is designed to capture returns and market risk rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include, but are not limited to, inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - A managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade multiple derivative instruments, including options, futures, forwards, or spot contracts, each of which may be tied to commodities, financial indices and instruments, foreign currencies, or equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and costs. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees on each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost money during the period. Margin Risk - Securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting the loan, and, as a result, 28  the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - Market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - Because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - A money market fund is technically a security. Fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. An investor can lose some or all of their principal if the share price decreases. The SEC has noted that "While investor losses in money market funds have been rare, they are possible." In return for this risk, an investor should earn a greater return on their cash than they would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Additionally, money market fund rates are variable. In other words, an investor does not know how much they will earn on their investment month to month, as the rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and earns less than expected, the investor may need more cash. Money market funds are also subject to inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at returns. Municipal Securities Risks -Mmunicipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project, like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - Mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short- term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager who trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stocks, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open- end" mutual funds continue to allow new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and 29  inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with the performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - Investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Political & Legislative Risk - Companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - An account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - Investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- A private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - An adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - Real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and rising concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - A real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must 30  refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - We may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same kind of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk - The risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - This occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm, including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts (on tangibles and intangibles) - A futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index at a specified price on a specified future date. Unlike options, the holder may or may not choose to exercise; futures contracts must be purchased for the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include, but are not limited to, futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor, requiring that the investor sell futures contracts at a loss. Short-Sales Risk - Short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - Securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - There are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health and the issuer. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - Although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength, demand for products or services. Stock Market Risk - The market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - Individual institutions may be restricted from directly utilizing some investment strategies that the Adviser may engage. Such institutions, including entities subject to ERISA, should consult 31  their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - An adviser's investment strategies and techniques may not work as intended. Structured Products Risk - A structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always FDIC insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - These are risks related to a broad universe of investments. These risks are also known as non- diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - For all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - At times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - Identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - These are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - A warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company. In contrast, options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. 32  Withdrawal of Capital Risks - An Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains; they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Advisor Representative before investing in digital assets or Bitcoin. Options Contracts - Options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The risks for options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a particular option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stop you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run significant risks if the position goes into substantial losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise in that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours, such that the writer of those options cannot perform effective remedy actions. 33  - Writers of stock options are obligated under the options that they sell, even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - Futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration. In contrast, the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Integrated does not represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed, may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternative securities or commodities. Any of the above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods, and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Item 9: Disciplinary Information ________________________________________________________________________________________________ Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Advisor Representatives 34  on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Advisor Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10: Other Financial Industry Activities & Affiliations ________________________________________________________________________________________________ Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. While Integrated does not maintain material relationships with the above entities except as disclosed, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Registered Representative of Broker-Dealer Integrated is not registered and does not intend to register as a broker-dealer. Still, in connection with their approved outside business activities, some Associates are Registered Representatives (“RRs”) of non-affiliated broker-dealers, Members of FINRA/SIPC. Associates with these unaffiliated broker-dealers can provide brokerage services as an RR of the unaffiliated broker-dealer firm. When acting in the capacity of an RR, the Associates will sell, for commissions, general securities products. They will receive commission-based compensation in connection with the purchase and sale of such securities, including 12b-1 fees for the sale of investment company products. If your Advisor Representative offers brokerage products as an RR through their unaffiliated broker-dealer, they are not acting in a brokerage capacity or on behalf of Integrated concerning the services provided under our Agreement(s). Integrated is not involved in the transaction and receives no compensation for the Associate's outside business activity. Associates who provide brokerage services through unaffiliated broker-dealers are independent contractors of such companies. Any compensation earned by these individuals in their capacities as RRs is separate, in addition to, and not related to our advisory fees or Agreement to provide advisory services. Clients are under no obligation to use the firm's Associates’ services in this different capacity as broker-dealer employees. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with the Adviser. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Associates' recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Insurance Services Some Associates are licensed as independent insurance agents through non-affiliated insurance companies offering fixed, fixed index, variable annuities, life, or long-term care universal life or other insurance products, and insurance services clients may decide to use Integrated for financial planning or investment advisory services. In these capacities, Integrated Advisor Representatives can recommend to firm clients and receive separate, yet customary, commission compensation, including bonuses and trail commissions, resulting from the purchases and sales of these products from the insurance agencies with whom they are presently or with whom they may become appointed in the future, in addition to their 35  compensation from Integrated. Such commissions and advisory fees are separate from the firm's advisory fees and Agreements, and clients are under no obligation, contractually or otherwise, to purchase insurance products or receive investment advice through insurance-licensed Associates in their capacities as insurance agents and/or Integrated Advisor Representatives. Pension Consulting & Employee Benefit Plan Services Certain DBAs and Advisor Representatives provide pension consulting and employee benefit plan advisory services, including plan design, investment policy development, manager selection, performance monitoring, participant education, and fiduciary support. In some cases, Associates may act as pension consultants or provide advice to plan sponsors and participants. These services may involve additional compensation and present potential conflicts of interest, which are disclosed and mitigated through adherence to fiduciary duty and Integrated’s Code of Ethics. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated, which sets forth the terms of the Agreement and the form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Advisor receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Securities Ownership Interest AllSource Investment Management Justin Bernier, Founding Partner of AllSource Investment Management, serves as Chief Executive of the National Security Emerging Markets Index ETF (“NSI ETF”). Mr. Bernier maintains a minority ownership interest in National Security Index, LLC (“NSI, LLC”), the sponsor and owner of the NSI ETF, and receives pro-rata distributions from the profits generated by the NSI ETF. Certain other Associated Persons of AllSource also hold ownership interests in NSI, LLC. These financial arrangements create a conflict of interest because Mr. Bernier and AllSource have an economic incentive to recommend the NSI ETF to clients. In addition to any advisory fees charged for portfolio management services, Mr. Bernier benefits financially from client investments in the NSI ETF through his ownership interest, resulting in a dual source of compensation. This conflict is fully disclosed to ensure transparency and informed decision-making by clients. To mitigate this conflict, Integrated employs an independent due diligence process to ensure that all investment recommendations—including those involving the NSI ETF—are made in clients’ best interest. This process includes objective evaluation of investment options, consideration of client-specific needs and goals, and documentation of the rationale for each recommendation. Sub-Advisory Services to Third-Party Managers Integrated and certain DBAs may serve as sub-advisers to unaffiliated third-party investment advisers, providing portfolio management services to clients of those advisers. Under these arrangements, the third-party adviser is responsible for client relationships and selection of strategies, while Integrated manages the designated assets according to the selected strategy. Integrated receives sub-advisory fees for these services, which are disclosed in the relevant agreements. Clients should refer to their third-party adviser’s disclosure documents for details on these relationships and associated fees. Tax Preparation Services Advisory clients may choose to use non-affiliated independent tax preparation services. And clients of the tax preparation providers may decide to use Integrated for financial planning and/or investment advisory services. Although Associates will make clients aware of the availability of tax preparation services, advisory clients are not required to utilize such services. 36  Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-added providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise- neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than the client's need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and revealing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Advisory Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ________________________________________________________________________________________________ Code of Ethics Rule 204A-1 of the Investment Advisers Act of 1940 requires all investment advisors registered with the Securities and Exchange Commission to adopt codes of ethics that set forth standards of conduct and comply with federal securities laws. Integrated takes its regulatory and compliance obligations seriously and recognizes its statutory duty to oversee the advisory activities of the supervised personnel who act on its behalf. The adviser believes each of its advisory clients is owed the highest level of trust and fair dealing and holds Associates to a very high standard of business practices and integrity. To that end, Integrated has adopted a Code of Ethics that sets forth the firm's conduct standards in keeping with its fiduciary obligation. Integrated's Code imposes upon Associates the duty to deal fairly and: 1. Render disinterested and impartial advice. 2. Make suitable recommendations to clients within the context of the total portfolio, given their needs, financial circumstances, and investment objectives. 3. Exercise a high degree of care to ensure that all material facts are disclosed to clients. 4. Provide adequate and accurate representations of its business and other information about Integrated's services and investment recommendations. 5. Disclose any conflicts of interest. 37  6. Promote fair, ethical, and equitable practices. The Adviser's Code requires all Associates to exercise a fiduciary duty by acting in each client’s best interest while consistently placing client interests first and foremost. The Code applies to all Integrated Associates, including individuals registered with the adviser as Advisor Representatives or considered 'Supervised Persons' under the Advisers Act Rules. The Code may also be applied to any other person the Chief Compliance Officer designates. Integrated's Code outlines and prohibits certain activities deemed to create conflicts of interest (or at least the potential for or the appearance of such a conflict) and specifies reporting requirements and enforcement procedures. Associates must abide fully by all applicable industry regulations and the firm’s guiding principles as outlined in its written supervisory Policies & Procedures Manual and Code, including any updates. The Code requires an affirmative commitment by Associates that they will abide by all state and federal securities laws and provisions relating to client information confidentiality, a prohibition on insider trading, restrictions on the acceptance of significant gifts, outside activities reporting, and personal securities trading procedures for Covered Persons, among others. Upon employment or affiliation and at least annually after that, Associates are required to attest to their understanding of, and compliance with, the Adviser’s Code of Ethics, including confirmation and acknowledgment by every licensed Advisor Representative of the firm’s expectations regarding their conduct, given the duties, responsibilities, and principles required of them. And execute an affirmation stating they will conduct business honestly, ethically, and fairly, avoiding all circumstances that might negatively affect or appear to affect their duty of complete loyalty to all clients. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested in before or after, suggesting them to clients, thus potentially profiting from the recommendations provided. Or combine our securities orders with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because they allow trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to strive to ensure that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific securities for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our firm or persons associated with our firm may buy or sell securities for you at the same time we or persons associated with our firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our firm nor persons associated with our firm shall have priority over your account in the purchase or sale of securities. 38  Trade Errors If a trading error occurs in your account, our policy is to restore your account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12: Brokerage Practices ________________________________________________________________________________________________ Preferred Custodians & Brokers-Dealers Integrated does not maintain custody of the assets we manage on our clients’ behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Advisory Agreement execution and enter into a separate broker-dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), and TD Ameritrade (TD Ameritrade Institutional, a division of TD Ameritrade, Inc. or “TDA”), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, Fidelity, and TD Ameritrade as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good-faith determination that the amount of the commission charged is reasonable, given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • The combination of transaction execution services along with asset custody services, generally offered without a separate fee for custody. • The capability to execute, clear, and settle trades - buy and sell securities for a client’s account. • Ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc. • Competitive trading commissions costs. • Reporting tools, including cost basis and 1099 reports facilitating tax management strategies. • Personal money management tools such as electronic fund transfer capabilities, dividend reinvestment programs, and electronic communication delivery capabilities. • Financial stability to ensure individual accounts, including primary and backup account insurance. • The breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc. • The availability of investment research and tools that assist us in making investment decisions. • Customer service levels and quality of services. • The competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them. • The reputation, financial strength, and stability of the provider. • The custodian’s prior service to our clients and us. • As discussed below, the availability of other products and services which benefit us. Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their clients access to institutional brokerage, trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Contact us directly for current qualifying amount numbers.) 39  Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some that the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist in managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: Includes pricing and other market data. • Provides access to client account data (such as duplicate trade confirmations and account statements). • Facilitates trade execution and allocates aggregated trade orders for multiple client accounts. • • Facilitate the payment of our fees from our clients’ accounts. • Assists with back-office functions, recordkeeping, and client reporting. Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: • Educational conferences and events. • Technology, compliance, legal, and business consulting. • Publications and conferences on practice management and business succession. • Access to employee benefits providers, human capital consultants, and insurance providers. Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research-related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no- transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. 40  Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non-research and research portions of the services received and pay Integrated money ("hard dollars") for the non-research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation that Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those of other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction, recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place-specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service. Soft dollar benefits are used to service all client accounts, not only those that pay for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence that our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodians' services not only benefit us. 41  Custodial Statements Clients will receive, at a minimum, quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated strongly encourages clients to promptly review all statements received directly from their custodian or other sources upon receipt to verify the accuracy of account transactions. Clients should also compare the investment performance of their account(s) against an appropriate benchmark for the types of investments held, as well as any periodic reports or information provided by Integrated. Please note that reports generated by Integrated may differ from custodial statements due to variations in accounting procedures, reporting dates, or valuation methodologies for certain securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Advisory Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Integrated in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; Integrated will not seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for different accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account that would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401(k) Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our firm or persons associated with our firm may buy or sell securities for you while buying or selling such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our firm nor persons associated with our firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) 42  Client Participation In Transactions Integrated makes investment decisions and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages and restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13: Review of Accounts ________________________________________________________________________________________________ No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon the client's request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed account solutions program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the advisory Agreement or as required under Rule 206(4)-2 of the Advisers’ Act. Additional reports can be provided on an ad hoc basis. 43  Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and MAS services, clients will direct their custodian to send them statements at least quarterly and provide Integrated duplicate copies of all periodic statements and other reports for the account the custodian sends to the client. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the account value at the beginning and end of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month, clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian, alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Advisers’ Act. Additional or more frequent reports can be provided according to Integrated Advisor Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Integrated directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be reconfirmed in writing. Item 14: Client Referrals & Other Compensation ________________________________________________________________________________________________ Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered into an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who 44  comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest, according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Advisor Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside-referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, Integrated does not compensate any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate, should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15: Custody ________________________________________________________________________________________________ Custodial Practices Integrated's typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Integrated is not authorized to withdraw any money, securities, or other property from any client custodial account in the client's name or otherwise. However, Integrated is deemed to have custody of certain client assets solely because one or more of its investment advisor representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the investment adviser representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. 45  Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process is generally more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. The client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed. 2. The client authorizes integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time. 3. The client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer. 4. The client can terminate or change the instruction to the client's custodian. 5. 6. 7. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction. Integrated maintains records showing that the third party is not a related party of the adviser or located at the same address as the adviser. In writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program Manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16: Investment Discretion ________________________________________________________________________________________________ Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Integrated will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • Determine the security to buy or sell. • Determine the amount of security to buy or sell. • Determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Integrated complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Advisor Representative may agree to from time to time - collectively, the “Investment Guidelines.” 46  Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types, or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian. Integrated will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Advisor Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization. Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Advisor Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Integrated reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Integrated engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed-upon investment objectives, Integrated reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Integrated will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17: Voting Client Securities ________________________________________________________________________________________________ Proxy Voting Integrated will not ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Integrated may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. 47  Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class- action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Integrated will not advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Integrated does not provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy, and is not obligated to forward copies of class action notices received to clients or their agents. Item 18: Financial Information ________________________________________________________________________________________________ Balance Sheet Integrated does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated nor its management has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self-regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. Disciplinary Disclosures Certain of Integrated's financial professionals have legal or disciplinary histories to disclose. Please visit the United States Securities and Exchange Commission's ("SEC") website at www.adviserinfo.sec.gov for a free and simple search tool to research Integrated and its financial professionals, management members, officers, and firm principals. Item 19: Additional Information ________________________________________________________________________________________________ Business Continuity Plan Overview Securities industry regulations require that investment advisers inform their clients of their plans to address the possibility of significant business disruption ("SBD") from unexpected events such as power outages, natural disasters, or other such occurrences. Firms must be able to provide continuous and uninterrupted services to their clients, and critical systems must function during such incidents so that the firm can resume operations as quickly as possible, given the SBD's scope and severity. 48  In addition, they must meet their obligations to clients, counterparties, and others during any emergency or SBD. Since the timing and impact of disasters and disruptions are unpredictable, firms must be flexible in acting. Well-thought- out, advanced preparations and effective procedures can significantly minimize downtime in the face of a disaster or outage. To satisfy this requirement, Integrated has developed a comprehensive Business Continuity Plan ("BCP" or "Plan") to detail how it will react when faced with such conditions. While no contingency plan can eliminate all service interruption risks, Integrated's BCP strives to set forth the firm's policies and practices under various SBD situations and mitigate all credible threats while keeping up with changes to the Adviser's business, structure, operations, and location. Firm Policy Integrated's guiding principle is that protecting clients, employees/Associates and family members always takes precedence over preserving business assets. Accordingly, Integrated's policy is to respond to an SBD by first safeguarding the lives of its clients, employees/Associates, family members, and others, and then firm property, making a quick financial and operational assessment, protecting and preserving all advisory books and records, and promptly recovering and resuming operations to allow clients to continue to transact business as rapidly as possible. Recovery times may vary depending on the nature and severity of the disruption; however, the objective of restoring mission-critical operations is 0-72 hours. BCP Summary Integrated's BCP - reviewed, tested regularly, and updated no less than annually- anticipates two kinds of SBDs, internal and external. Internal SBDs affect only the firm's ability to communicate and do business, such as a fire in the building. External SBDs prevent the operation of the securities markets for several firms and may include terrorist attacks, floods, or wide-scale regional disruptions. Integrated's BCP addresses all mission-critical systems, office closing and relocation procedures, and employee alternative physical locations. In addition, regulatory reporting and alternative communications between the Adviser and its clients, employees, critical business constituents, banks, counterparties, regulators, and others are detailed to preserve uninterrupted communication. The Plan also defines data backup and recovery procedures (hard copy and electronic) and succession planning in the event of crucial personnel absence. Further, Integrated requires its primary internal and external vendor systems providers to periodically verify and test their backup capabilities to promptly provide the necessary information and applications to continue or resume business in an emergency or SBD situation. Integrated carries out its BCP under the direction of the Disaster Recovery Executive Coordinator (the "DREC"). The DREC is responsible for making an immediate preliminary assessment of the nature and extent of any disruption and communicating the firm's BCP to employees, clients, critical business constituents, and regulators. When an internal or external event, either minor or significant, occurs or appears to be developing, Integrated's DREC will be notified. Upon notification or becoming aware of an SBD event, the DREC will implement BCP emergency procedures, secure the headquarters as much as possible, and advise all employees to call the firm's emergency line directly @ 855.729.4222. The Adviser will transfer its operations to a local worksite if a business disruption affects only Integrated or a specific area within the firm. If a disruption affects the firm's business district, city, or region, operations will be transferred to an alternate worksite outside the affected area. Telephone service will continue, and regular work processes will resume at its alternate location(s). Integrated will continue conducting business in either situation and notify its clients about maintaining contact through a message recorded on its main phone number and website posting. Integrated does not maintain custody of client funds or securities; clients maintain all account assets at an independent qualified custodian with whom they can always communicate and access assets directly, with or without the Adviser's intervention. In the event of an SBD, Integrated will help facilitate client access to these external accounts by resolving their questions, providing status updates, and offering up-to-date contact information to assist them in reaching their custodians and, if applicable, for the type of account opened, any third-party managers ("TPMs") directly. If an SBD also impacts a client's custodian or TPM or cannot otherwise be reached, Integrated will generate a bulk email via the firm's then-current Internet-based communications platform to inform the situation and safeguard clients' awareness of developments. Integrated will also relay communications to custodians and TPMs on the client's behalf. If an SBD is so severe that it prevents the firm from conducting advisory business, Integrated will promptly update its voice message and website. If it is determined that the firm cannot continue its advisory business, clients will be assured swift access to their funds, securities, and prepaid fees by direct contact with their respective custodians and TPMs (as 49  applicable). Additional Information Integrated's BCP is designed to allow the firm to continue to provide the quality service its clients have come to expect. Please contact us directly at 855.729.4222 with any questions regarding this topic. Information Security Program Integrated maintains an Information Security Program to reduce the risk of clients' personal and confidential information breaches. Please contact us directly at 855.729.4222 with any questions regarding this topic. Privacy Practices Your relationship with us is based on trust and confidence. This privacy policy ("Privacy Policy" or “Policy”) describes the ways Integrated Advisors Networks, LLC collects, stores, uses, discloses, and protects the privacy of the personally identifiable and non-personally identifiable information we may collect from you or that you may provide. Our goal is to treat the information you furnish us with the utmost respect, following this Policy and safeguard and protect the information you have provided securely and professionally. We remain committed to this objective. What is Personally Identifiable Information? Personally identifiable information ("PII") describes the information associated with you. It can be used to identify you and includes your name, address, phone number, zip code, e-mail address, and other similar data. Non-personally identifiable information (“non-PII”) is information that does not identify a specific person or is publicly available. Non- PII may include, for example, your IP address, browser type, domain names, access dates, and similar information. Categories of Information We Collect The personal information we collect and share will depend on the product or service. Confidential personal data collected about you can include, but not be limited to: • • • Information we receive from you via applications or other forms, such as your name, address, phone number, or social security number, occupation, assets, and income. Investment experience and other financial and family information. Information about your transactions with us or the brokerages, banks, and custodians with whom you hold investment or cash accounts, including account numbers, holdings, balances, transaction history, and other financial and investment activities. How We Collect Your Information We collect your personal information; for example, when you seek investment advice, tell us about your investment portfolio(s), open an account, make account deposits or withdrawals, or provide your income details. We also collect your personal information from others, such as other companies. We do not knowingly solicit information from or market our products or services to children. How We Use Your Information We may use information that we collect about you or that you provide to us, including any personal information, for any purpose, including but not limited to: Improve, modify, customize, and measure our services. • Personalize our contact with you, or verify your identity when accessing our services. • Compare information for accuracy and record verification. • Provide information, materials, products, or the services you request. • • Develop new products and services. • Send you administrative messages, content, and other services and features in which we believe you may be interested. • Provide you with information about our products and services, including while you are on our website online services or after you visit such online services. • Contact you for the potential purchase of insurance or other financial products. • Operate, provide, improve, and maintain our website to prevent abusive and fraudulent use of our website or enforce our terms of use and any other agreements between you and our firm. • For any other administrative and internal business purposes permitted by law. 50  Sharing Non-Public Personal & Financial Information Financial companies must share customers' personal information to run their everyday business and provide services. Even when required to do this, we are committed to the protection and privacy of your personal and financial information. We will share your personal information with only those non-affiliated third-party service providers authorized to use your data as necessary to support our business operations, such as: In connection with a sale or merger of our business. In any circumstance that has your instruction or consent. • When necessary to complete an account transaction, such as with the clearing firm or account custodians. • When required to maintain or service an account. • For marketing services. • When requested by a fiduciary or beneficiary on the account. • When required by a regulatory agency or for other reasons required or permitted by law. • To our attorneys, accountants, or compliance consultants. • To provide customer service or resolve customer disputes. • To provide data storage, payment, or technology support and services. • For risk solution provisions, analytics, or fraud prevention. • • The personal information we share for business purposes may include any categories of personal information identified in this Privacy Policy that we may collect. Protection of Personal Information We maintain various security measures to protect against the loss, misuse, and alteration of the information under our control. We restrict access to personal and account information to only those employees who need to know the information to provide products or services to you. Physical, electronic, and procedural safeguards are in place to guard client data using security measures that comply with federal law, such as computer protection, secured files, and buildings. Finally, although no business can wholly guarantee that information will remain free from unauthorized access, use, disclosure, or alteration, we make consistent, diligent, and good-faith efforts to maintain information security, utilizing safety measures designed to prevent unauthorized access or usage. Internet Use You can visit us on the Internet at www.integratedavisorsnetwork.com without telling us who you are or revealing any information about yourself, including your e-mail address. In this case, our web servers may collect the domain name you used to access the Internet, such as www.aol.com, the website you came from and visited next, and other data. We use this data to monitor site performance and make the site more accessible and convenient. (Please visit us at www.integratedavisorsnetwork.com to review our website "Terms of Service.") Sharing Information & Consumer Choice When you provide information to us, we may share your information, to the extent provided by applicable law, with our affiliated companies and third parties to fulfill your requests and offer you other services that may interest you. Your information is not shared with any third party unless requested by you or permitted by law. Under no circumstances will we sell or transfer your information to any ad network, ad exchange, data broker, or other advertising or monetization- related service. We may also aggregate statistics about our customers, sales, traffic patterns, and services and provide these statistics to third parties; however, when we do, the statistics will exclude any personal information that identifies individuals. We will not provide your personal information to mailing list vendors or Promoters. We require strict confidentiality in our agreements with unaffiliated third parties that need access to your personal data, including financial service companies, consultants, and auditors. Federal and state securities regulators may review our firm and your records as the law permits. Federal law allows you to limit sharing information about your creditworthiness for affiliates' everyday business purposes, affiliates from using your information to market to you, and sharing with non-affiliates to market to you. State and international laws and individual companies may provide additional rights to limit sharing. (Contact us directly for specific state and residence privacy requirements.) 51  Notification In the Event of A Data Breach Although we make reasonable efforts to maintain your information securely, no firm or individual can guarantee that shared information will remain free from unauthorized access, use, disclosure, or alteration. If an unauthorized party breaches your personally identifiable information, we will comply with applicable state laws in notifying you of the breach. Former Customers Personally identifiable information about you will be maintained while you are a client and for the crucial period after that, as federal and state securities laws require, if you close your account(s) or become an inactive customer. After that time, information may be destroyed. Accessing or Correcting Your Information You may access your data collected by us by sending a request to the address below. If you believe that an error has been made in the accuracy of the information collected from you, we will correct such error upon adequate verification of the error and the person's identity seeking the correction. If you wish to access, remove, or correct any personally identifying information you have supplied to us or have any questions about this Privacy Policy, you may contact us by sending a letter to the address on the cover of this Brochure. Changes to Our Privacy Policy We reserve the right to modify or supplement Integrated's Privacy Policy statement at any time. If we make any material changes, we will notify our existing clients and update our website to reflect such changes, including disclosing the Policy's last revised date. Questions Please contact us as follows if you have any questions or concerns regarding our privacy or business practices: INTEGRATED ADVISORS NETWORK, LLC P.O. Box 25523 Dallas TX 75225 Telephone: 855.729.4222 Fax: 310.742.0227 www.integratedavisorsnetwork.com 52 

Item 1 – Cover Sheet JC Investment Management Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 1100 Lake Street, Ste 210G Oak Park, IL 60301 708-948-7092 March 31, 2026 the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler This Brochure provides information about the qualifications and business practices of JC Investment Management. If you have any questions about the contents of this Brochure, please contact us at 708-948-7092. Alternatively, contact at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfo@sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ............................................................................................................................................... 1 Item 2 – Material Changes ....................................................................................................................................... 2 Item 3 – Table of Contents ...................................................................................................................................... 4 Item 4 – Advisory Business ..................................................................................................................................... 5 Item 5 – Fees and Compensation ........................................................................................................................... 16 Item 6 – Performance Fees .................................................................................................................................... 19 Item 7 – Types of Clients ....................................................................................................................................... 19 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................................... 20 Item 9 – Disciplinary Information ......................................................................................................................... 33 Item 10 – Other Financial Industry Activities and Affiliations ............................................................................. 34 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................ 36 Item 12 – Brokerage Practices ............................................................................................................................... 37 Item 13 – Review of Accounts .............................................................................................................................. 42 Item 14 – Client Referrals and Other Compensation ............................................................................................. 44 Item 15 - Custody .................................................................................................................................................. 45 Item 16 – Investment Discretion ............................................................................................................................ 46 Item 17 – Voting Client Securities ........................................................................................................................ 47 Item 18 – Financial Information ............................................................................................................................ 48 4  Item 4 – Advisory Business Description of the Advisory Firm JC Investment Management is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter “the Adviser”, “Associate” or “JC Investment”. Integrated Advisors Network, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. JC Investment Management is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Chris Lynn is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, 5  and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is 7  compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should 9  consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options’ appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial 10  practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning JC Investment Management through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. JC Investment Management may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. 13  There is an inherent conflict of interest for JC Investment Management whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. JC Investment Management or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of JC Investment Management Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and 14  objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee 15  that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of JC Investment Management’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. 16  (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management The fees and compensation payable to the Adviser are negotiable and vary among its clients. Client will pay the Adviser a fee for its investment advisory services. The specific manner in which fees are charged by the Adviser is established in a client’s written agreement with the Adviser. The fee will be calculated on a quarterly basis and collected in advance. There is a tiered structure with a maximum of 0.95%. The tiered rate is calculated based on the total Household balances under the Adviser’s management at the end of the previous quarter. The tiered rate structure is as follows: • 0.95% of the first $1,000,000 • 0.90% of the amount between $1,000,000 and $3,000,000 • 0.85% of the amount between $3,000,000 and $5,000,000 • 0.5% of the amount above $5,000,000 The fee will be calculated in the same manner for all clients; however, the fee is negotiable. Fee Billing Investment management fees are deducted quarterly in advance. Account values are based upon pricing information supplied by the client’s third- party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the Investment Advisory Agreement. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The clients of JC Investment Management will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the 17  individual brochure for each advisory group for specific details. JC Investment’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that JC Investment’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) 18  Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients Description The Adviser provides portfolio management services to individuals, high net worth individuals, trusts, corporate and small business profit-sharing plans, and plan participants of corporate and small business retirement plans. There are no account minimum sizes. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. 19  Account Minimums To open and maintain a portfolio management account, the Advisor generally requires that the client represents and warrants that the value of their account initially is at least $50,000. At the Advisor’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an 20  accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. 21  When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. 22  The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. 23  Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the 24  risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, 25  increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by 26  revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. 27  Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the 28  same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. 29  Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price 30  before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. 31  The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for 32  all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. 33  On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the businesses are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of JC Investment Management. Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. JCIM and associated persons do not participate in any of the above business activities. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. 34  Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. JC Investment Management and its associated persons do not have any other financial industry activities or affiliations. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. 35  Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of 36  all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and 37  Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, • provides access to client account data (such as duplicate trade confirmations and account statements), • 38  includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and 39  attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. 40  Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists 41  because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. 42  Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. 43  Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. 44  Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. 45  The Adviser will require: 1. 2. 3. the client provide an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the 46  introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. 47  While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 48 

Item 1 – Cover Page Lattice Wealth Management Group, Inc. Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 84 W Santa Clara St Suite 734 San Jose, CA 95113 5401 Business Park South, Suite 208 Bakersfield, CA 93309 201 Spear St., Suite 1100 San Francisco, CA 94105 mylatticewealth.com March 31, 2026 This Brochure provides information about the qualifications and business practices of Lattice Wealth Management Group Inc. If you have any questions about the contents of this Brochure, please contact us at 708-948-7092 or call the Chief Compliance Officer at 855-729-4222 or by email at compliance@integratedadvisorsnetwork.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Registration as an investment adviser with the SEC does not imply a certain level of skill or training. Additional information about the Advisor also is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: On April 7, 2025, Lattice Wealth Management moved its business location to 84 W Santa Clara St, Suite 734 San Jose, CA 95113. Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) 2  Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling (cid:27)(cid:24)(cid:24)(cid:4137)(cid:26)(cid:21)(cid:28)(cid:4137)(cid:23)(cid:21)(cid:21)(cid:21)(cid:15)(cid:3)(cid:82)(cid:85)(cid:3)(cid:89)(cid:76)(cid:86)(cid:76)(cid:87)(cid:76)(cid:81)(cid:74)(cid:3)www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Page .................................................................................................................................................1 Item 2 – Material Changes .......................................................................................................................................2 Item 3 – Table of Contents .......................................................................................................................................4 Item 4 – Advisory Business ......................................................................................................................................5 Item 5 – Fees and Compensation ........................................................................................................................... 17 Item 6 – Performance Fees ..................................................................................................................................... 20 Item 7 – Types of Clients ....................................................................................................................................... 20 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................................ 21 Item 9 – Disciplinary Information .......................................................................................................................... 21 Item 10 – Other Financial Industry Activities and Affiliations .............................................................................. 34 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................... 37 Item 12 – Brokerage Practices ................................................................................................................................ 39 Item 13 – Review of Accounts ............................................................................................................................... 44 Item 14 – Client Referrals and Other Compensation ............................................................................................. 45 Item 15 – Custody .................................................................................................................................................. 46 Item 16 – Investment Discretion ............................................................................................................................ 47 Item 17 – Voting Client Securities ......................................................................................................................... 49 Item 18 – Financial Information ............................................................................................................................. 49 4  Item 4 – Advisory Business Description of Firm Lattice Wealth Management Group Inc. is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter “the Advisor”, “Associate” or “Lattice Wealth”. Integrated Advisors Network, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. Lattice Wealth is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Mike Ross and Arnell Land are Investment Adviser Representatives (“IARs”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a 5  percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is 7  compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: - Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. - Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - Charge no more than is reasonable for our services. - Give you basic information about conflicts of interest. Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: - Employer retirement plans generally have a more limited investment menu than IRAs, and - Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. - You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should 9  consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial 10  practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. (cid:120) Assessment assistance of the client’s investment needs and objectives. (cid:120) (cid:120) Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. (cid:120) Recommendations on appropriate style allocations. (cid:120) (cid:120) Evaluation of asset managers and investment vehicles meeting style and allocation criteria. (cid:120) Engagement of selected asset managers and investment vehicles on behalf of the client. (cid:120) Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. (cid:120) Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. (cid:120) Recommendations for account rebalancing, if necessary. (cid:120) Online reporting of the client account’s performance and progress. (cid:120) Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. (cid:120) Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Lattice Wealth through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Lattice Wealth may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. 13  There is an inherent conflict of interest for Lattice Wealth whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Lattice Wealth or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of Lattice Wealth. Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Educational Seminars & Workshop Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third 14  party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: (cid:120) Cash, cash equivalents, and money market funds (cid:120) Corporate and/or municipal debt securities (cid:120) Digital Assets / Bitcoin (cid:120) Equities (stocks) (cid:120) Exchange-traded funds (“ETFs”) (cid:120) Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities (cid:120) Options contracts (including limited use for hedging or income strategies, where appropriate) (cid:120) U.S. government securities (cid:120) Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. 15  Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. 16  Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Lattice Wealth’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Management Fee Increasingly, the Advisor has clients’ accounts billed on a flat quarterly fee. This fee reflects the type of work done for the client and adjusted annually based on pre-determined measures of success. In legacy accounts, the client will pay the Advisor a fee for its investment advisory services. The specific manner in which fees are charged by the Advisor is established in a client’s written agreement with the Advisor. The fee will be calculated on a monthly basis and collected in advance. There is a fee range between 0.10% and 1.50% and based on a range of factors unique to each client. The fee will be calculated in the same manner for all clients; however, the fee is negotiable. 17  Financial Planning/Tangible Property Fees The Financial Planning fee will be determined based on the nature of the services being provided and the complexity of each client’s circumstances. All fees are agreed upon prior to entering into a contract with any client. As our fee is based on each client’s personal situation, the complexity of the service, and time commitment required, we will provide an estimate of the total fee at the start of the advisory relationship. Financial planning fees are negotiable but generally fees are charged at the rate of $200 to $300 an hour or for a fixed fee that generally ranges from $1,000 to $25,000. The Advisor may also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. This is considered an integral part of the financial planning process and does not generate a separate fee. On occasion, the Advisor may enter into an agreement to offer financial consultation at a similar hourly rate as the financial planning rate. When the client seeks to have the Advisor to provide more administrative roles that do not constitute financial advice, the Advisor will charge an hourly fee for service. Such hourly rate will be competitive with similar providers in that geographical area. Fee Billing Investment management fees and fixed fees are deducted monthly in advance. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the Investment Advisory Agreement. Hourly billed fees are invoiced and deducted from the clients’ account monthly in arrears. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The clients of Lattice Wealth will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Lattice Wealth’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Lattice Wealth’s fees are the lowest available for similar services. 18  Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. 19  The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients Description The Advisor provides portfolio management services to individuals, high net worth individuals, non-profit organizations, trusts, corporate and small business profit-sharing plans, and plan participants of corporate and small business retirement plans. Account Minimums To open and maintain a portfolio management account, the Advisor generally requires that the client represents and warrants that the value of their account initially is at least $50,000. At the Advisor’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. 20  Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. 21  Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. 22  Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: 23  (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. 24  Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the 25  purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the 26  underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. 27  Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, 28  and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a 29  company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, 30  indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. 31  Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. 32  - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. - Risk of erroneous reporting of exercise value. - - If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate 33  within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. 34  Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the businesses are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Lattice Wealth. Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client 35  or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser Registered Representative of Broker-Dealer Integrated is not registered and does not intend to register as a broker-dealer. Still, in connection with their approved outside business activities, some Associates are Registered Representatives (“RRs”) of non-affiliated broker- dealers, Members of FINRA/SIPC. Associates with these unaffiliated broker-dealers can provide brokerage services as an RR of the unaffiliated broker-dealer firm. When acting in the capacity of an RR, the Associates will sell, for commissions, general securities products and will receive commission-based compensation in connection with the purchase and sale of such securities, including 12b-1 fees for the sale of investment company products. If your Adviser Representative offers brokerage products as an RR through their unaffiliated broker-dealer, they are not acting in a brokerage capacity or on behalf of Integrated concerning the services provided under our Agreement(s). Integrated is not involved in the transaction and receives no compensation for the Associate's outside business activity. Associates who provide brokerage services through unaffiliated broker-dealers are independent contractors of such companies. Any compensation earned by these individuals in their capacities as RRs is separate, in addition to, and not related to our advisory fees or Agreement to provide advisory services. Clients are under no obligation to use the firm's Associates’ services in this different capacity as broker-dealer employees. Insurance Services Lattice Wealth and/or certain associated persons of Lattice Wealth may sell insurance products to advisory clients. Some Associates are licensed as independent insurance agents through non-affiliated insurance companies offering fixed, fixed index, variable annuities, life, or long-term care universal life or other insurance products, and insurance services clients may decide to use Integrated for financial planning or investment advisory services. In these capacities, Integrated Adviser Representatives can recommend to firm clients and receive separate, yet customary, commission compensation, including bonuses and trail commissions, resulting from the purchases and sales of these products from the insurance agencies with whom they are presently or with whom they may become appointed in the future in addition to their compensation from Integrated. Such commissions and advisory fees are separate from the firm's advisory fees and Agreements, and clients are under no obligation, contractually or otherwise, to purchase insurance products or receive investment advice through insurance-licensed Associates in their capacities as insurance agents and/or Integrated Adviser Representatives. 36  Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. 37  As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. 38  Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: (cid:120) (cid:120) (cid:120) the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, (cid:120) (cid:120) (cid:120) personal money management tools such as electronic fund transfer capabilities, dividend reinvestment (cid:120) (cid:120) (cid:120) (cid:120) (cid:120) programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. (cid:120) (cid:120) (cid:120) Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow 39  the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. (cid:120) provides access to client account data (such as duplicate trade confirmations and account statements), (cid:120) (cid:120) (cid:120) (cid:120) Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. (cid:120) (cid:120) (cid:120) publications and conferences on practice management and business succession, and (cid:120) Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) 40  Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services 41  may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost 42  the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. 43  Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. 44  According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At 45  the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 – Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional 46  information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: 47  (cid:120) determine the security to buy or sell, (cid:120) determine the amount of security to buy or sell, and (cid:120) determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. 48  Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in 49  an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 50 

Item 1 – Cover Sheet LIENART FAMILY ASSET MANAGEMENT Form ADV Part 2A – Firm Brochure 42158 Sand Dune Drive Palm Desert, CA 92211 (707) 280-5172 March 31, 2026 This brochure provides information about the qualifications and business practices of Lienart Family Asset Management. If you have any questions about the contents of this brochure, please contact us at (707) 280- 5172, or by email at lance@lienartfamilyassetmanagement.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ................................................................................................................................................1 Item 2 – Material Changes .......................................................................................................................................2 Item 3 – Table of Contents .......................................................................................................................................4 Item 4 – Advisory Business ......................................................................................................................................5 Item 5 – Fees and Compensation ........................................................................................................................... 16 Item 6 – Performance Fees ..................................................................................................................................... 19 Item 7 – Types of Clients ....................................................................................................................................... 20 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................................ 20 Item 9 – Disciplinary Information .......................................................................................................................... 33 Item 10 – Other Financial Industry Activities and Affiliations .............................................................................. 34 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................... 36 Item 12 – Brokerage Practices ................................................................................................................................ 37 Item 13 – Review of Accounts ............................................................................................................................... 42 Item 14 – Client Referrals and Other Compensation ............................................................................................. 44 Item 15 - Custody ................................................................................................................................................... 45 Item 16 – Investment Discretion ............................................................................................................................ 46 Item 17 – Voting Client Securities ......................................................................................................................... 47 Item 18 – Financial Information ............................................................................................................................. 48 4  Item 4 – Advisory Business Description of Firm Lienart Family Asset Management is a dba of the registered entity Integrated Advisors Network LLC, collectively hereinafter “the Adviser”, “Associate” or “Lienart”. Integrated Advisors Network, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. Lienart is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Lance Lienart is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a 5  percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is 7  compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should 9  consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial 10  practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Lienart through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Lienart may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. 13  There is an inherent conflict of interest for Lienart whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Lienart or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of Lienart. Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory 14  relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee 15  that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Leinart’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) 16  Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management The Adviser bases its range of fees as a percentage of assets under management. Although the Investment Management Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance therefore at termination any unearned fees as determined on a pro rata basis for the portion of the month completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Adviser and fees for comparable services may be available from other sources. Annualized Investment Management Fees Incremental Account Value From $0 $1,000,001 $2,000,001 $5,000,001 $10,000,001 Over Incremental Account Value To $1,000,000 $2,000,000 $5,000,000 $10,000,000 $15,000,000 $15,000,001 Annual Percentage Fee 1.00% .95% .90% .85% .80% .75% Fee Billing Investment management fees will be billed and deducted quarterly. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. 17  Integrated Fee Disclosure The clients of Lienart will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Lienart’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Lienart’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. 18  Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. 19  Item 7 – Types of Clients Description The Adviser provides services to institutions, individuals, high net worth individuals, pension and profit-sharing plans directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser does not have an account minimum. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. 20  Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. 21  While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. 22  Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. 23  Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. 24  Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each 25  underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, 26  when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with 27  significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of 28  risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. 29  Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price 30  before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. 31  The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for 32  all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without 33  admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Lienart. Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the 34  promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Insurance Affiliations Lance Lienart is also independently licensed as an insurance agent and may sell insurance products to clients and receive commissions when doing so. Some Associates are licensed as independent insurance agents through non- affiliated insurance companies offering fixed, fixed index, variable annuities, life, or long-term care universal life or other insurance products, and insurance services clients may decide to use Integrated for financial planning or investment advisory services. In these capacities, Integrated Adviser Representatives can recommend to firm clients and receive separate, yet customary, commission compensation, including bonuses and trail commissions, resulting from the purchases and sales of these products from the insurance agencies with whom they are presently or with whom they may become appointed in the future in addition to their compensation from Integrated. Such commissions and advisory fees are separate from the firm's advisory fees and Agreements, and clients are under no obligation, contractually or otherwise, to purchase insurance products or receive investment advice through insurance-licensed Associates in their capacities as insurance agents and/or Integrated Adviser Representatives. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates 35  communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. 36  Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody 37  Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our 38  clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. 39  Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. 40  Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. 41  Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client 42  financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from 43  Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. 44  Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's 45  conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” 46  as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. 47  While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 48 

Item 1 – Cover Sheet Long Course Capital Form ADV Part 2A – Firm Brochure 2121 Avenue of the Stars, Suite 1400 Los Angeles, CA 90067 310-612-3331 www.longcoursecapital.com March 31, 2026 This brochure provides information about the qualifications and business practices of Long Course Capital LLC. If you have any questions about the contents of this brochure, please contact us at: (310) 612-3331, or by email at: audra@longcoursecapital.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ................................................................................................................................................1 Item 2 – Material Changes ........................................................................................................................................2 Item 3 – Table of Contents .......................................................................................................................................4 Item 4 – Advisory Business ......................................................................................................................................5 Item 5 – Fees and Compensation ............................................................................................................................ 16 Item 6 – Performance Fees ..................................................................................................................................... 19 Item 7 – Types of Clients........................................................................................................................................ 19 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................................ 19 Item 9 – Disciplinary Information .......................................................................................................................... 33 Item 10 – Other Financial Industry Activities and Affiliations .............................................................................. 33 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................... 35 Item 12 – Brokerage Practices ................................................................................................................................ 37 Item 13 – Review of Accounts ............................................................................................................................... 42 Item 14 – Client Referrals and Other Compensation .............................................................................................. 43 Item 15 – Custody ................................................................................................................................................... 44 Item 16 – Investment Discretion ............................................................................................................................. 45 Item 17 – Voting Client Securities ......................................................................................................................... 47 Item 18 – Financial Information ............................................................................................................................. 47 4  Item 4 – Advisory Business Firm Description Long Course Capital, LLC is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter (“the Advisor”, “Associate: or “Long Course”). Integrated Advisors Network, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. Long Course is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Audra Mallow is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a 5  percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is 7  compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should 9  consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial 10  practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Long Course through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Long Course may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. 13  There is an inherent conflict of interest for Long Course whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Long Course or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of Long Course. Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory 14  relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. 15  Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Long Course’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) 16  Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management The Advisor bases its fees on a percentage of assets under management. Although the Investment Management Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. The investment management fee is generally 1.00% of assets under management. Fee Billing Investment management fees are billed quarterly, in arrears, based on the average daily account balance of the previous quarter of the assets held in the Account(s). Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The clients of Long Course will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Long Course’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Long Course’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of 17  mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. 18  Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients Description The Advisor provides services to high-net-worth individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, corporations, and other business entities. Client relationships vary in scope and length of service. Other advisory groups of Integrated provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Advisor generally requires that the client represents and warrants that the value of their account initially is at least $1,000,000. At the Advisor’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and 19  liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. 20  Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. 21  Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary 22  dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. 23  Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' 24  claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a 25  margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting 26  their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such 27  information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. 28  Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield 29  of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. 30  Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. 31  Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using 32  AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Long Course. 33  Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while 34  focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Long Course and associated persons do not participate in any of the above business activities. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell 35  specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. 36  Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • 37  Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar 38  amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), 39  Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. 40  Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. 41  Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. 42  After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. 43  Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 – Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled 44  investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. 45  Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake 46  minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. 47  Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 48 

Item 1 – Cover Sheet Longview Investment Advisors Form ADV Part 2A – Firm Brochure 101 Federal St. 19th Floor Boston, MA 02110 617-624-4105 www.longviewinvestments.com March 31, 2026 This brochure provides information about the qualifications and business practices of LongView Investment Advisors. If you have any questions about the contents of this brochure, please contact us at: (415) 999-2162 or the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler, at (855) 729-4222 or compliance@integratedadvisorsnetwork.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Adviser is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or “the Firm”) is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Effective March 1, 2026, LongView Investment Advisors moved its principal office to 101 Federal St. 19th Floor Boston, MA 02110, and closed its former office location at 75 Arlington Street, 5th Fl. Boston, MA 02116. Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost- effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. 2  Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. free of charge at www.integratedadvisorsnetwork.com, by You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ................................................................................................................................................1 Item 2 – Material Changes .......................................................................................................................................2 Item 3 – Table of Contents .......................................................................................................................................4 Item 4 – Advisory Business......................................................................................................................................5 Item 5 – Fees and Compensation ........................................................................................................................... 17 Item 6 – Performance Fees and Side-By-Side Management .................................................................................. 20 Item 7 – Types of Clients ....................................................................................................................................... 20 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................................ 20 Item 9 – Disciplinary Information .......................................................................................................................... 34 Item 10 – Other Financial Industry Activities and Affiliation ............................................................................... 34 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................... 36 Item 12 – Brokerage Practices ................................................................................................................................ 36 Item 13 – Review of Accounts ............................................................................................................................... 43 Item 14 – Client Referrals & Other Compensation ................................................................................................ 43 Item 15 – Custody .................................................................................................................................................. 46 Item 16 – Investment Discretion ............................................................................................................................ 47 Item 17 – Voting Client Securities ......................................................................................................................... 48 Item 18 – Financial Information ............................................................................................................................. 49 4  Item 4 – Advisory Business Description of Firm Longview Investment Management is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter “the Adviser”, “Associate” or “Longview”. Integrated Advisors Network, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. Longview is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Chuck Brown and Niki Rukstalis Boyson an Investment Adviser Representatives (“IARs”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will 5  range from a percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: 7  “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: 8  Employer retirement plans generally have a more limited investment menu than IRAs, and - Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - 2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) 9  any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third-Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the 10  deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly- owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third- Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. 11  • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub- managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third-party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. 12  PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Longview through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. 13  The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Longview may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. There is an inherent conflict of interest for Longview whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Longview or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of Longview. Educational Seminars & Workshop Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. (See Item 10: Other Financial Industry Activities & Affiliations.) Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and 14  procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. 15  Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified 16  time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Integrated's Form ADV Part 2A Brochure and the applicable DBA Advisor Representative’s Part 2B Brochure Supplement will be provided to clients before or at the time of client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution, without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management & Supervisory Services Adviser provides investment management and supervisory services on a fee-only basis based on the value of the assets to be managed, the work to be provided, and the complexity of their situation. If engaged, Adviser will charge an annual fee of up to 1.00%, based upon a percentage of the market value of the client’s assets under management, calculated and billed consistently with the Adviser’s disclosure documents and each client’s contracts’ compensation arrangements. Individual client account fees will vary depending on the selected Program’s investment options and the fee schedule of each Integrated advisory group’s practices. However, in all cases, the Advisor Representative's advisory practices must ensure that the advisory fees they assess clients are accurate, up-to-date, and aligned with Integrated’s disclosures, up to the maximum annual rates listed herein. Clients should refer to the individual brochure of each advisory group for specific details. (Note: Lower fees for comparable services can sometimes be available from other sources.) Each client's executed Agreement will indicate final advisory fees and fee-payment arrangements before the delivery of any advisory services. Educational Seminars & Workshop Fees Educational seminars and workshops are provided free of charge. 17  Fee Billing The annual investment management and supervisory services fees are prorated, billed quarterly or monthly, and payable in arrears according to the client’s Agreement, based on a percentage of assets under management based on the average daily balance of the preceding quarter or month. The first quarter’s or month’s fees shall be calculated on a pro-rata basis. Clients will choose the frequency at which they wish to be billed and indicate their fee billing preference on their advisory services Agreement. Clients may have their fees directly debited from the account held at their custodian of record. Integrated will not access client funds for fees without written client consent. Clients who wish to have their fees directly debited will authorize the Integrated in writing to deduct any advisory fees due from their custodial account directly and provide their custodian with authorization to deduct such amounts when due and remit them straight to Integrated. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) The client’s custodian will deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The clients of Longview will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Longview’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Longview’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. 18  The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost- effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher 19  management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees and Side-By-Side Management Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance-based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance-based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients Client Types Discretionary and non-discretionary investment advice and management supervisory services are typically provided to individuals, high-net-worth individuals, trusts, estates, charitable organizations, pension & profit- sharing plans, corporations and business entities. Client relationships vary in scope and length of service. Minimum Account Size Investment management and supervisory services and ERISA - retirement and employee benefit plan services clients do not have a minimum account size requirement. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. 20  Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the 21  option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC- insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting 22  method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, 23  because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks 24  may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, 25  requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. 26  Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non- public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying 27  Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably 28  available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. 29  Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre-packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations 30  in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. 31  Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. 32  - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. - Risk of erroneous reporting of exercise value. - If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client 33  service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. 34  Item 10 – Other Financial Industry Activities and Affiliation Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Longview. Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria 35  and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Longview and its associated persons do not have any other financial industry activities or affiliations. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. 36  Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. 37  Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, • • • • 38  • the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. 39  Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non- research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. 40  In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non-research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed 41  brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the 42  client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. 43  Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals & Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. 44  Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. 45  Item 15 – Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client-directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. 46  Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre- approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. 47  For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. 48  Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 49 

Item 1 – Cover Sheet Menlo Oaks Capital Group Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 885 Oak Grove Avenue, Suite 208 Menlo Park, CA 94025 (650) 375-2636 March 31, 2026 This brochure provides information about the qualifications and business practices of Menlo Oaks Capital Group, LLC. If you have any questions about the contents of this brochure, please contact us at (650) 375- 2636, or by email at pwhite@menlooakscapital.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ................................................................................................................................................1 Item 2 – Material Changes ........................................................................................................................................2 Item 3 – Table of Contents .......................................................................................................................................4 Item 4 – Advisory Business ......................................................................................................................................5 Item 5 – Fees and Compensation ............................................................................................................................ 17 Item 6 – Performance Fees ..................................................................................................................................... 19 Item 7 – Types of Clients ....................................................................................................................................... 20 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................................ 20 Item 9 – Disciplinary Information .......................................................................................................................... 34 Item 10 – Other Financial Industry Activities and Affiliations .............................................................................. 34 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................... 36 Item 12 – Brokerage Practices ................................................................................................................................ 38 Item 13 – Review of Accounts ............................................................................................................................... 43 Item 14 – Client Referrals and Other Compensation .............................................................................................. 44 Item 15 - Custody ................................................................................................................................................... 45 Item 16 – Investment Discretion ............................................................................................................................. 46 Item 17 – Voting Client Securities ......................................................................................................................... 48 Item 18 – Financial Information ............................................................................................................................. 48 4  Item 4 – Advisory Business Firm Description Menlo Oaks Capital Group LLC is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter “the Advisor”, “Associate” or “Menlo Oaks Capital Group” or “Menlo Oaks”. Integrated Advisors Network, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. Menlo Oaks is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Pat White is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a 5  percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is compensated creates conflicts with your interests, so we operate under a special rule that requires us to act 7  in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should 9  consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial 10  practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Menlo Oaks through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Menlo Oaks may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. 13  There is an inherent conflict of interest for Menlo Oaks whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Menlo Oaks or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of Menlo Oaks. Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. 14  Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. 15  Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. 16  Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Menlo Oaks’ Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management The Advisor bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance. The investment management fees are negotiable at the sole discretion of the Advisor and fees for comparable services may be available from other sources. The Advisor’s Fee can range from 1.00% through 2.00%, depending upon the passive or active nature of the portfolio. Financial Planning Fees Financial Planning for clients without $300,000+ under management and for complex situations is provided under a fixed fee arrangement agreed upon at the first meeting and based on an hourly rate ranging between $100 - $250. Fifty percent of the fee is payable in advance, before the financial planning process is started. The remaining fifty percent is payable at the end of the engagement. Fee Billing Investment management fees will be billed quarterly in advance. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not 17  verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The clients of Menlo Oaks will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Menlo Oaks’ fees may be higher or lower than other advisory groups at Integrated and there is no representation that Menlo Oaks’ fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. 18  If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. 19  Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients Description The Advisor provides services to institutions, individuals, high net worth individuals, pension and profit- sharing plans, trusts, estates or charitable organizations, and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Advisor generally requires that the client represents and warrants that the value of their account initially is at least $50,000. At the Advisor’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. 20  Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling 21  securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the 22  performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay 23  current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform 24  accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. 25  Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange 26  Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. 27  Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. 28  Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. 29  However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or 30  continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific 31  period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. 32  Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. 33  Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Menlo Oaks. Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 34  10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Insurance Services Menlo Oaks and/or certain associated persons of Menlo Oaks may sell insurance products to advisory clients. Some Associates are licensed as independent insurance agents through non-affiliated insurance companies offering fixed, fixed index, variable annuities, life, or long-term care universal life or other insurance products, and insurance 35  services clients may decide to use Integrated for financial planning or investment advisory services. In these capacities, Integrated Adviser Representatives can recommend to firm clients and receive separate, yet customary, commission compensation, including bonuses and trail commissions, resulting from the purchases and sales of these products from the insurance agencies with whom they are presently or with whom they may become appointed in the future in addition to their compensation from Integrated. Such commissions and advisory fees are separate from the firm's advisory fees and Agreements, and clients are under no obligation, contractually or otherwise, to purchase insurance products or receive investment advice through insurance-licensed Associates in their capacities as insurance agents and/or Integrated Adviser Representatives. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall 36  receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. 37  Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • 38  Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar 39  amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), 40  Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. 41  Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. 42  Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. 43  After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. 44  Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because 45  one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. 46  Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake 47  minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. 48  Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 49 

Item 1 – Cover Sheet MILITELLO WEALTH MANAGEMENT Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 650B Pierce Blvd. O'Fallon, IL 62269 (314) 655-2118 www.milwm.com March 31, 2026 This brochure provides information about the qualifications and business practices of Militello Wealth Management, LLC. If you have any questions about the contents of this brochure, please contact us by telephone at (314) 655-2118, or by email at rickm@milwm.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729- 4222 The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) 2  Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ................................................................................................................................................1 Item 2 – Material Changes .......................................................................................................................................2 Item 3 – Table of Contents .......................................................................................................................................4 Item 4 – Advisory Business ......................................................................................................................................5 Item 5 – Fees and Compensation ............................................................................................................................ 17 Item 6 – Performance Fees ..................................................................................................................................... 21 Item 7 – Types of Clients ...................................................................................................................................... 22 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................................ 22 Item 9 – Disciplinary Information .......................................................................................................................... 35 Item 10 – Other Financial Industry Activities and Affiliations .............................................................................. 36 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................ 38 Item 12 – Brokerage Practices ................................................................................................................................ 40 Item 13 – Review of Accounts ............................................................................................................................... 45 Item 14 – Client Referrals and Other Compensation ............................................................................................. 46 Item 15 - Custody ................................................................................................................................................... 47 Item 16 – Investment Discretion ............................................................................................................................. 48 Item 17 – Voting Client Securities ......................................................................................................................... 50 Item 18 – Financial Information ............................................................................................................................. 51 4  Item 4 – Advisory Business Description of Firm Militello Wealth Management, LLC., is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter "the Advisor", “Associate(s)” or “Militello Wealth". Integrated Advisors Network, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. Militello Wealth is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Rick Militello, Anna Militello and Blake Feldmann are Investment Adviser Representatives (“IARs”) of Integrated Advisors Network, LLC. Integrated’s advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, 5  and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is compensated creates conflicts with your interests, so we operate under a special rule that requires us to act 7  in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should 9  consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third-Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial 10  practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Militello Wealth through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Militello Wealth may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. 13  There is an inherent conflict of interest for Militello Wealth whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services Militello Wealth or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of Militello Wealth. Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Educational Seminars & Workshop Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third 14  party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. 15  Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. 16  Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Militello Wealth’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management The Advisor bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client's discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance; therefore, at termination, any unearned fees as determined on a pro-rata basis for the portion of the month completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Advisor, and fees for comparable services may be available from other sources. 17  Annual Fee Managed Assets 1.55% Under $1,000,000 1.30% Over $1,000,000 Negotiable Over $5,000,000 Investment management fees will be billed and deducted quarterly. For advance fee billing accounts, we invoice you before the three-month billing period has begun, based on the asset value of your account on the last day of the previous quarter. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client's third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Financial Planning Services You are advised that fees for planning services are strictly for planning services. Therefore, you will pay fees and/or commissions for additional services obtained, such as asset management or products purchased such as securities or insurance. Fees are negotiable. Your fees will be dependent on several factors, including time spent with Militello Wealth, the number of meetings, the complexity of your situation, the amount of research, services requested, and staff resources. Fee Type Maximum Fee Fixed Fee $2,000 to $25,000 Payable A payment schedule will be negotiated and customized to the client. Advisor and client will agree on a fee payment schedule and outline the terms in the advisory agreement between Advisor and client. Client will not be charged more than $500 and six or more months in advance. Hourly Fee $50 to $200 per hour A payment schedule will be negotiated and customized to the client. Advisor and client will agree on a fee payment schedule and outline the terms in the advisory agreement between Advisor and client. Client will not be charged more than $500 and six or more months in advance. Termination Provisions You may terminate advisory services obtained from Militello Wealth, without penalty, upon written notice within five (5) business days after entering into the advisory agreement with Militello Wealth. Thereafter, you may terminate investment advisory services with written notice to Militello Wealth. You will be responsible for any time spent by Militello Wealth. Retirement Plan Consulting Services Militello Wealth will bill the Company for Retirement Plan Consulting Services at a pre-determined fee based upon a percentage of the Plan assets or a flat agreed-upon fee. The exact fee is negotiated in advance of services rendered and is disclosed in the executed written agreement that we sign with the Company. Fees will be billed quarterly in advance. In special circumstances, other fee-paying arrangements are negotiated. 18  Termination Provisions The service will continue until terminated by you. You may terminate advisory services obtained from Militello Wealth, without penalty, upon written notice within five (5) business days after entering into the advisory agreement with Militello Wealth. Thereafter, you may terminate investment advisory services with 30 days written notice to Militello Wealth. If fees were paid in advance, you will be refunded a prorated portion of the advisory fee. Retirement Plan Consulting Services fee schedule is as follows: Value of Plan Assets Up to $2,500,000 $2,500,000 to $5,000,000 $5,000,000 to $10,000,000 Max Annual Fee 0.80% 0.60% 0.50% $10,000,000 to $20,000,000 0.40% $20,000,000 to $30,000,000 $30,000,000 to $50,000,000 0.25% 0.20% Over $50,000,000 0.10% Fee-based on the value of plan assets. Fees are negotiable. Fees for partial quarters will be prorated. Alternatively, the Company can elect to pay a fixed annual fee billed in quarterly installments in advance of each quarter. The fixed fee will not exceed $75,000. Fee Billing Fees will be billed and deducted quarterly. For advance fee billing accounts, we invoice you before the three-month billing period has begun, based on the asset value of your account on the last day of the previous quarter. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client's third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. 19  Integrated Fee Disclosure The clients of Militello will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Militello’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Militello’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. 20  Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. 21  Item 7 – Types of Clients Description The Advisor provides services to institutions, individuals, high net worth individuals, pension, and profit-sharing plans directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Advisor does not have an account minimum. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of 22  the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. 23  While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. 24  Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. 25  Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. 26  Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each 27  underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, 28  when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with 29  significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of 30  risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. 31  Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price 32  before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. 33  The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for 34  all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. 35  On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Militello Wealth. Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, 36  which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Registered Representative of Broker-Dealer Integrated is not registered and does not intend to register as a broker-dealer. Still, in connection with their approved outside business activities, some Associates are Registered Representatives (“RRs”) of non-affiliated broker- dealers, Members of FINRA/SIPC. Associates with these unaffiliated broker-dealers can provide brokerage services as an RR of the unaffiliated broker-dealer firm. When acting in the capacity of an RR, the Associates will sell, for commissions, general securities products and will receive commission-based compensation in connection with the purchase and sale of such securities, including 12b-1 fees for the sale of investment company products. If your Adviser Representative offers brokerage products as an RR through their unaffiliated broker-dealer, they are not acting in a brokerage capacity or on behalf of Integrated concerning the services provided under our Agreement(s). Integrated is not involved in the transaction and receives no compensation for the Associate's outside business activity. Associates who provide brokerage services through unaffiliated broker-dealers are independent contractors of such companies. Any compensation earned by these individuals in their capacities as RRs is separate, in addition to, and not related to our advisory fees or Agreement to provide advisory services. Clients are under no obligation to use the firm's Associates’ services in this different capacity as broker-dealer employees. 37  Insurance Services Militello Wealth and/or certain associated persons of Militello Wealth may sell insurance products to advisory clients. Some Associates are licensed as independent insurance agents through non-affiliated insurance companies offering fixed, fixed index, variable annuities, life, or long-term care universal life or other insurance products, and insurance services clients may decide to use Integrated for financial planning or investment advisory services. In these capacities, Integrated Adviser Representatives can recommend to firm clients and receive separate, yet customary, commission compensation, including bonuses and trail commissions, resulting from the purchases and sales of these products from the insurance agencies with whom they are presently or with whom they may become appointed in the future in addition to their compensation from Integrated. Such commissions and advisory fees are separate from the firm's advisory fees and Agreements, and clients are under no obligation, contractually or otherwise, to purchase insurance products or receive investment advice through insurance-licensed Associates in their capacities as insurance agents and/or Integrated Adviser Representatives. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest 38  personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in 39  such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, • 40  the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client 41  accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. 42  Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. 43  While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account 44  to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate 45  information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and 46  Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other 47  property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the 48  relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. 49  Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. 50  Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 51 

Item 1 – Cover Sheet Miller Pacific Financial Advisors Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 80 Sir Francis Drake Blvd. Suite 3A Larkspur, CA 94939 (415) 524-8089 www.millerpacadvisors.com March 31, 2026 This brochure provides information about the qualifications and business practices of Miller Pacific Financial Advisors. If you have any questions about the contents of this brochure, please contact us at (415) 524-8089, or by email at leslie@millerpacadvisors.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ................................................................................................................................................1 Item 2 – Material Changes .......................................................................................................................................2 Item 3 – Table of Contents .......................................................................................................................................4 Item 4 – Advisory Business .....................................................................................................................................5 Item 5 – Fees and Compensation ........................................................................................................................... 17 Item 6 – Performance Fees .................................................................................................................................... 20 Item 7 – Types of Clients ....................................................................................................................................... 21 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................................ 21 Item 9 – Disciplinary Information ......................................................................................................................... 34 Item 10 – Other Financial Industry Activities and Affiliations ............................................................................. 35 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................... 37 Item 12 – Brokerage Practices ............................................................................................................................... 38 Item 13 – Review of Accounts ............................................................................................................................... 43 Item 14 – Client Referrals and Other Compensation .............................................................................................. 45 Item 15 - Custody ................................................................................................................................................... 46 Item 16 – Investment Discretion ............................................................................................................................ 47 Item 17 – Voting Client Securities ......................................................................................................................... 48 Item 18 – Financial Information ............................................................................................................................ 49 4  Item 4 – Advisory Business Description of Firm Miller Pacific Financial Advisors is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter “the Adviser”, “Associate” or “Miller Pacific”. Integrated Advisors Network, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. Miller Pacific is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Leslie Miller is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a 5  percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is compensated creates conflicts with your interests, so we operate under a special rule that requires us to act 7  in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other 9  important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. Miller Pacific Financial Advisors does not use this service. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third-Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) 10  Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Miller Pacific through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs Miller Pacific may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. 13  There is an inherent conflict of interest for Miller Pacific whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services Miller Pacific or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of Miller Pacific. Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Wealth Coaching, Second Opinions & Financial Analysis Fees Miller Pacific may provide coaching services that typically do not include investment advisory or management services, financial planning services, nor the review or monitoring of a client’s investment portfolio. The Adviser may recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Adviser. If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. It remains the client’s responsibility to promptly notify the Adviser if there is ever any change in his/her/its situation for the purpose of reviewing/evaluating/revising the Adviser’s previous recommendations and/or services. Educational Seminars & Workshop Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the 14  Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. (See Item 10: Other Financial Industry Activities & Affiliations.) Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. 15  As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to 16  be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Miller Pacific Financial Advisors’ Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. 17  Investment Management The Adviser bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected quarterly in advance; therefore, at termination any unearned fees as determined on a pro rata basis for the portion of the quarter completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Adviser and lower fees for comparable services may be available from other sources. This fee includes standard financial planning for Households with Assets Under Management above $700,000. Household Assets Under Management Annual Fee $100,000 - $249,000 $250,000 - $499,999 $500,000 - $999,999 $1,000,000 - $1,999,999 $2,000,000 - $4,999,999 Above $5,000,000 1.35% 1.20% 1.00% 0.85% 0.60% Fixed Fee Financial Planning Fees Financial Planning for clients without $700,000+ assets under management and for complex situations is provided under a fixed or hourly fee arrangement agreed upon at the first meeting and based on hourly rates of $300 for professionals, $150 for paraprofessionals, and $40 for administrative services. Twenty-five percent of the fee is payable in advance before the financial planning process is started. The remainder is payable during the engagement. The financial planning fees are negotiable at the sole discretion of the Adviser and fees for comparable services may be available from other sources. Wealth Coaching, Second Opinions & Financial Analysis Fees MPFA provides a range of education, coaching, and analysis services including "second opinions" on existing investment portfolios. These services are provided based on an hourly rate of $300 for professionals, $150 for paraprofessionals, and $40 for administrative services. A retainer fee is payable at initiation of project and the balance is payable monthly as invoiced. Fee Billing Investment management fees will be collected quarterly in advance. Fees are calculated based on the asset value of accounts on the last day of the previous quarter. Account values are determined based upon information supplied by the client’s third- party qualified custodians, where their accounts are held. Fees are deducted from client accounts as authorized by the investment management agreement. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to 18  Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The clients of Miller Pacific Financial Advisors will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Miller Pacific Financial Advisors’ fees may be higher or lower than other advisory groups at Integrated and there is no representation that Miller Pacific Financial Advisors’ fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services 19  for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these 20  conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients Description The Adviser provides services to institutions, individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates, charitable organizations and corporations, or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated provide services to other types of clients than are disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser generally requires that the client represents and warrants that the value of their account initially is at least $500,000. At the Adviser’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid 21  companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your 22  portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, 23  and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. 24  Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations 25  in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative 26  instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. 27  Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). 28  Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. 29  Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term 30  because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. 31  Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. 32  - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are 33  subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. 34  On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Our firm offers services through our network of investment advisor representatives ("Advisor Representatives" or "IARs"). IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The Client should understand that the businesses are legal entities of the IAR and not of our firm Integrated Advisors Network. The IARs are under the supervision of our firm Integrated Advisors Network. Integrated Advisors Network has the arrangement described above with the IARs of Miller Pacific. Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only 35  provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Miller Pacific Financial Advisors does not have any other financial industry activities or affiliations. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. 36  Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, 37  its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: 38  • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • 39  Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. 40  A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. 41  Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require 42  fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are 43  conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they 44  should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation 45  received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly 46  after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. 47  Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. 48  Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 49 

Item 1 – Cover Sheet Mosaic Financial Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 40 Philadelphia Drive, Suite 101 Chico, CA 95973 (307) 256-6931 www.mosaicfinancialsolutions.com March 31, 2026 This brochure provides information about the qualifications and business practices of Mosaic Financial Solutions, LLC. If you have any questions about the contents of this brochure, please contact us at: (307) 256-6931, or by email at: anna@mosaicfinancialsolutions.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) This section also corrects a typographical error to state the billing is done quarterly in arrears. Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) 2  Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ................................................................................................................................................1 Item 2 – Material Changes .......................................................................................................................................2 Item 3 – Table of Contents .......................................................................................................................................4 Item 4 – Advisory Business ......................................................................................................................................5 Item 5 - Fees and Compensation ............................................................................................................................ 17 Item 6 – Performance Fees ..................................................................................................................................... 20 Item 7 – Types of Clients ....................................................................................................................................... 20 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................................ 21 Item 9 – Disciplinary Information .......................................................................................................................... 34 Item 10 – Other Financial Industry Activities and Affiliations .............................................................................. 35 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................... 37 Item 12 – Brokerage Practices ................................................................................................................................ 38 Item 13 – Review of Accounts ............................................................................................................................... 43 Item 14 – Client Referrals and Other Compensation ............................................................................................. 45 Item 15 – Custody .................................................................................................................................................. 46 Item 16 – Investment Discretion ............................................................................................................................ 47 Item 17 – Voting Client Securities ......................................................................................................................... 47 Item 18 – Financial Information ............................................................................................................................. 49 4  Item 4 – Advisory Business Description of Firm Mosaic Financial Solutions, LLC, is a dba of the registered entity Integrated Advisors Network LLC, hereinafter collectively referred to as “the Adviser”, “Associate” or “Mosaic”. Integrated Advisors Network, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. Mosaic is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Anna Nelson is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a 5  percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is compensated creates conflicts with your interests, so we operate under a special rule that requires us to act 7  in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should 9  consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third-Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial 10  practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Mosaic through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Mosaic may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. 13  There is an inherent conflict of interest for Mosaic whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Mosaic or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of Mosaic. Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Educational Seminars & Workshop Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third 14  party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. 15  Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. 16  Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 - Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Mosaic’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management The Advisor bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in arrears. The investment management fees are negotiable at the sole discretion of the Advisor and fees for comparable services may be available from other sources. The Advisor’s fee can range from .60% to 1.0% depending upon the underlying factors of each portfolio. Financial Planning /Tangible Property Fees The Financial Planning fee will be determined based on the nature of the services being provided and the complexity 17  of each client’s circumstances. All fees are agreed upon prior to entering into a contract with any client. As our fee is based on each client's personal situation, complexity of the service, and time commitment required, we will provide an estimate of the total fee at the start of the advisory relationship. Financial planning fees are negotiable but generally fees are charged at the rate of $50 to $200 an hour or by a monthly subscription fee that generally ranges from $100 to $300. The Adviser may also provide general non‐ securities advice on topics that may include tax and budgetary planning, estate planning and business planning. This is considered an integral part of the financial planning process and does not generate a separate fee. On occasion, the Adviser may enter into an agreement to offer financial consultation at a similar hourly rate as the financial planning rate. Clients of the Adviser, however, are under no obligation to act upon any recommendations of the Adviser or to affect any transactions through the Adviser if they decide to follow the Adviser’s recommendations. Financial Planning Fixed Fee Financial Planning will generally be offered on a fixed fee basis. Financial Planning consists of an upfront set- up fee ranging from $500.00 - $2,500.00. There will be an ongoing monthly fee which will range from $100.00 - $300.00, per month, in advance. The fixed fee is determined by the complexity of the client’s needs and financial plan and will be agreed upon before the start of any work. In the event of early termination, the client will be billed for the hours worked at a rate of $200.00 per hour. If the initial deposit is greater than the amount billed, then the client will be refunded the difference. If the initial deposit is less, then the client will be billed the difference. Financial Planning Hourly Fee Financial Planning fee is an hourly rate between $50 to $200 per hour. The fee may be negotiable in certain cases and is due at the completion of the engagement. In the event of early termination by client, any fees for the hours already worked will be due. Fee Billing Investment management fees are billed quarterly, in arrears, based on the total market value of the account as shown on the Firm’s provided portfolio statement on the last business day of the month. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. 18  Integrated Fee Disclosure The clients of Mosaic will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Mosaic’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Mosaic’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. 19  Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients Description The Adviser provides services to institutions, individuals, high net worth individuals, pension and profit- sharing plans, trusts, estates or charitable organizations, and corporations or other business entities directly. client 20  relationships vary in scope and length of service. Other advisory groups of Integrated provide services to other types of clients than is disclosed herein. Account Minimums The Adviser in general, does not require a minimum dollar amount to open and maintain an advisory account. Pre- existing advisory client are subject to Mosaic Financial, LLC's minimum account requirements and advisory fees in effect at the time the client entered into the advisory relationship. Therefore, our Firm's minimum account requirements will differ among clients. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to 21  measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. 22  When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. 23  The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. 24  Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the 25  risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, 26  increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by 27  revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. 28  Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the 29  same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. 30  Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price 31  before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. 32  The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for 33  all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without 34  admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Mosaic. Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the 35  promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Mosaic Financial and its associated persons do not have any other financial industry activities or affiliations. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. 36  Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. 37  Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: 38  • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • 39  Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. 40  A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. 41  Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require 42  fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. 43  Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or 44  Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated 45  addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 – Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, 46  3. the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. 47  Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. 48  Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 49 

Item 1 – Cover Sheet Nspire Wealth Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 67 South Garfield St. Denver, CO 80209 (720)813-6856 www.nspire-wealth.net March 31, 2026 This brochure provides information about the qualifications and business practices of Nspire Wealth, LLC. If you have any questions about the contents of this brochure, please contact us at (303) 618-9061, or by email at: brenda@nspire-wealth.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................4 Item 4 – Advisory Business ........................................................................................................................................5 Item 5 – Fees and Compensation .............................................................................................................................. 17 Item 6 – Performance Fees ....................................................................................................................................... 20 Item 7 – Types of Clients ......................................................................................................................................... 21 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................................. 21 Item 9 – Disciplinary Information ............................................................................................................................ 21 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................ 35 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................... 37 Item 12 – Brokerage Practices .................................................................................................................................. 38 Item 13 – Review of Accounts ................................................................................................................................. 38 Item 14 – Client Referrals and Other Compensation ............................................................................................... 45 Item 15 - Custody ..................................................................................................................................................... 46 Item 16 – Investment Discretion .............................................................................................................................. 47 Item 17 - Voting Client Securities ............................................................................................................................ 47 Item 18 – Financial Information ............................................................................................................................... 49 4  Item 4 – Advisory Business Description of Firm Nspire Wealth, LLC is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter “the Adviser”, “Associate” or “Nspire Wealth”. Integrated Advisors Network, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC- registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. Nspire Wealth is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Brenda Cox is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a 5  percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is 7  compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should 9  consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third-Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial 10  practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Nspire Wealth through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Nspire Wealth may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. 13  There is an inherent conflict of interest for Nspire Wealth whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Nspire Wealth or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of Nspire Wealth. Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Educational Seminars & Workshop Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. (See Item 10: Other Financial Industry Activities & Affiliations.) Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third 14  party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. 15  Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. 16  Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Nspire Wealth’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management The Adviser bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance; therefore, at termination, any unearned fees as determined on a pro-rata basis for the portion of the quarter completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Adviser and fees for comparable services may be available from other sources. 17  Annualized Investment Management Fees Incremental Account Value From $0 $2,500,001 $5,000,001 $10,000,001 $25,000,001 $50,000,001 Over Incremental Account Value To $2,500,000 $5,000,000 $10,000,000 $25,000,000 $50,000,000 $100,000,000 $100,000,001 Annual Percentage Fee 2.00% 1.50% 1.25% 1.00% 0.80% 0.50% 0.40% Financial Planning Services The Adviser’s fees for planning services are strictly for planning services. Therefore, clients will pay fees and/or commissions for additional services obtained such as asset management or products purchased such as securities. Fees are negotiable. Client fees will be dependent on several factors, including time spent with Nspire Wealth, the number of meetings, the complexity of client situation, amount of research, services requested and resources. Fee Type Maximum Fee Payable The maximum hourly fee is $1,000 per hour. A payment schedule will be negotiated and customized to the client. The Adviser and client will agree on a fee payment schedule and outline the terms in the advisory agreement between the Adviser and client. A client will not be charged more than $500 in fees six months or more in advance. Consulting Services Nspire Wealth will bill clients Consulting Services at a pre-determined fee based upon a percentage of the assets. The exact fee is negotiated in advance of services rendered and is disclosed in the executed written agreement that we sign with the client. Fees will be billed quarterly in advance. In special circumstances, other fee-paying arrangements are negotiated. Fee Billing Investment management fees will be billed quarterly in advance. For advance fee billing accounts, we invoice you before the three-month billing period has begun, based on the asset value of your account on the last day of the previous quarter. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. 18  Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The clients of Nspire Wealth will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Nspire Wealth’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Nspire Wealth’s fees are the lowest available for similar services. The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that 19  outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. 20  Item 7 – Types of Clients Description The Adviser provides services to institutions, individuals, high net worth individuals, pension and firm plans, trusts, foundations, estates or charitable organizations, family offices, and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums The Adviser generally pursues clients with $10 million or more in net worth and $2 million in investment advisory assets. However, at its sole discretion, the Adviser may charge a lesser annual advisory fee or waive the stated client minimums based upon various factors, including, for example, anticipated future earning capacity, anticipated future assets, historical relationship, client investment experience, related accounts, account composition, negotiations with client, accounts referred to adviser by another professional, etc. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Clients will be required to sign investment advisory agreements (and/or other contractual arrangements) that, among other things, set forth the nature and scope of our investment advisory and management authority, specific services, and the investment objectives, guidelines, and restrictions applicable to the management of client accounts. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. 21  ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. 22  Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any 23  investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, 24  credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. 25  Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. 26  Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much 27  you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to 28  buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock 29  dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. 30  Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. 31  Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. 32  The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical 33  goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the 34  suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Nspire Wealth. Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. 35  Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Nspire and its associated persons do not have any other financial industry activities or affiliations. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates 36  communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. 37  Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody 38  Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our 39  clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. 40  Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. 41  Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. 42  Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client 43  financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from 44  Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. 45  Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client-directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's 46  conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” 47  as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 - Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. 48  While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 49 

Item 1 – Cover Sheet Open Network Financial Consulting Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 106 Fordham Road West Newton, MA 02465 (617) 797-7617 March 31, 2026 This brochure provides information about the qualifications and business practices of Open Network Financial Consulting. If you have any questions about the contents of this brochure, please contact us at (617) 797-7617, or by email at: marklublin@opennetworkfinancial.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729- 4222 The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................4 Item 4 – Advisory Business ........................................................................................................................................5 Item 5 – Fees and Compensation .............................................................................................................................. 17 Item 6 – Performance Fees ....................................................................................................................................... 20 Item 7 – Types of Clients ......................................................................................................................................... 21 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................................. 21 Item 9 – Disciplinary Information ............................................................................................................................ 35 Item 10 Other Financial Industry Activities and Affiliations ................................................................................... 35 Item 11 – Code of Ethics .......................................................................................................................................... 37 Item 12 – Brokerage Practices .................................................................................................................................. 39 Item 13 – Review of Accounts ................................................................................................................................. 44 Item 14 – Client Referrals and Other Compensation ............................................................................................... 45 Item 15 - Custody ..................................................................................................................................................... 46 Item 16 – Investment Discretion .............................................................................................................................. 47 Item 17 – Voting Client Securities ........................................................................................................................... 47 Item 18 Financial Information .................................................................................................................................. 49 4  Item 4 – Advisory Business Description of Firm Open Network Financial Consulting is a dba of the registered entity Integrated Advisors Network LLC, collectively hereinafter “the Adviser”, “Associate” or “Open Network”. Integrated Advisors Network, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. Open Network is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Mark Lublin is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a 5  percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is 7  compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should 9  consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third-Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial 10  practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Open Network through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Open Network may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. 13  There is an inherent conflict of interest for Open Network whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services Open Network or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of Open Network. Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Wealth Coaching, Second Opinions & Financial Analysis Fees Adviser may provide coaching services that typically do not include investment advisory or management services, financial planning services, nor the review or monitoring of a client’s investment portfolio. The Adviser may recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Adviser. If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. It remains the client’s responsibility to promptly notify the Adviser if there is ever any change in his/her/its situation for the purpose of reviewing/evaluating/revising the Adviser’s previous recommendations and/or services. Educational Seminars & Workshop Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to 14  schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When 15  recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client 16  assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Open Network’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. 17  Investment Management The Adviser bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance therefore at termination any unearned fees as determined on a pro rata basis for the portion of the quarter completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Adviser and fees for comparable services may be available from other sources. The Adviser’s Fee can range from .50% through 2.00%, depending upon the passive or active nature of the portfolio. Investment management fees will be billed quarterly in advance. For advance fee billing accounts, we invoice you before the three-month billing period has begun, based on the asset value of your account on the last day of the previous quarter. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Financial Planning Fees Financial Planning for clients, which includes complex situations is provided under a fixed fee arrangement agreed upon at the first meeting and billed monthly. These services can be provided based on either (a) an hourly rate of up to $350/hr.; (b) a range of $1500-$7500 for one off calculations or plans, or (c) through an annual subscription to wealth management, account aggregation and financial planning for those without assets under management, billed monthly up to $500 per person in the household. These rates are increased depending on the complexity and time involved with the engagement. Certain financial plans require fifty percent of the fee payable in advance before the financial planning process is started. The remaining fifty percent is then payable at the end of the engagement. Advisor will not charge a prepayment of more than $1200 in fees more than 6 months in advance. Wealth Coaching, Second Opinions & Financial Analysis Fees Open Network provides a range of education, coaching and analysis services including "second opinions" on existing investment portfolios. These services can be provided based on either (a) an hourly rate of $200/hr.; (b) a range of $500-$2500 for one off calculations or plans, or (c) through an annual subscription to wealth management, account aggregation & financial planning for those without assets under management, billed monthly at $1,200 annually per person in the household. Open Network may require that fifty percent of the fee be payable in advance, before the financial planning process is started. The remaining fifty percent is then payable at the end of the engagement. Fee Billing Investment management fees will be billed quarterly in advance. For advance fee billing accounts, we invoice you before the three-month billing period has begun, based on the asset value of your account on the last day of the previous quarter. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) 18  Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The clients of Open Network will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Open Network’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Open Network’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. 19  Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both 20  performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients Description The Adviser provides services to institutions, individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates or charitable organizations, and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser generally requires that the client represents and warrants that the value of their account initially is at least $250,000. At the Adviser’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. 21  ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. 22  Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any 23  investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, 24  credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. 25  Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. 26  Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much 27  you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to 28  buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock 29  dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. 30  Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. 31  Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. 32  The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical 33  goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the 34  suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Open Network. Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. 35  Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Insurance Services Open Network and/or certain associated persons of Open Network may sell insurance products to advisory clients. Some Associates are licensed as independent insurance agents through non-affiliated insurance companies offering fixed, fixed index, variable annuities, life, or long-term care universal life or other insurance products, and insurance services clients may decide to use Integrated for financial planning or investment advisory services. In these capacities, Integrated Adviser Representatives can recommend to firm clients and receive separate, yet customary, commission compensation, including bonuses and trail commissions, resulting from the purchases and sales of these products from the insurance agencies with whom they are presently or with whom they may become appointed in the future in addition to their compensation from Integrated. Such commissions and advisory fees are separate from the firm's advisory fees and Agreements, and clients are under no obligation, contractually or otherwise, to purchase 36  insurance products or receive investment advice through insurance-licensed Associates in their capacities as insurance agents and/or Integrated Adviser Representatives. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the 37  sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. 38  Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow 39  the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) 40  Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services 41  may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost 42  the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. 43  Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. 44  According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At 45  the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client-directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional 46  information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: 47  • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. 48  Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability 49  to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 50 

Item 1 – Cover Sheet Rama Financial, LLC Firm ADV Part 2- Firm Brochure (CRD #171991 / SEC #801-96203) Rama Financial, LLC 8717 N Circulo El Palmito Tucson, AZ 85704 www.ramafinancialllc.com March 31, 2026 Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler This brochure provides information about the qualifications and business practices of Rama Financial, LLC. If you have any questions about the contents of this brochure, please contact us at: (415) 999-2162. Alternatively, contact the at compliance@integratedadvisorsnetwork.com or call (855) 729-4222. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Adviser is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................4 Item 4 – Advisory Business ........................................................................................................................................5 Item 5 – Fees and Compensation .............................................................................................................................. 17 Item 6 – Performance Fees ....................................................................................................................................... 20 Item 7 – Types of Clients ......................................................................................................................................... 20 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................................. 20 Item 9 – Disciplinary Information ............................................................................................................................ 34 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................ 34 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................... 36 Item 12 – Brokerage Practices .................................................................................................................................. 38 Item 13 – Review of Accounts ................................................................................................................................. 43 Item 14 – Client Referrals and Other Compensation ............................................................................................... 44 Item 15 - Custody ..................................................................................................................................................... 44 Item 16 – Item Discretion ......................................................................................................................................... 46 Item 17 – Voting Client Securities ........................................................................................................................... 46 Item 18 – Financial Information ............................................................................................................................... 48 4  Item 4 – Advisory Business Description of Firm Rama Financial, LLC, does business under the registered entity Integrated Advisors Network, LLC, collectively hereinafter “the Adviser”, “Associate” or “Rama Financial”. Integrated Advisors, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. Rama Financial is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Duane Burghard is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a 5  percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Code Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is 7  compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should 9  consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third-Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial 10  practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Rama Financial through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Rama Financial may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. 13  There is an inherent conflict of interest for Rama Financial whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Rama Financial or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of Rama Financial. Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Educational Seminars & Workshop Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third 14  party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. 15  Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. 16  Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Rama Financial’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Fees are negotiable and may vary, but generally will be based on an annual percentage rate of 1% of assets under management. Fees are payable quarterly at the beginning of each calendar quarter based on the market value of the assets under management at the close of the prior quarter. Fees on additions or withdrawals are pro-rated. A client may terminate an investment advisory agreement with five (5) business days advance written notice. On termination, clients may receive a refund of advisory fees on a pro-rated basis. Adviser prefers to have management fees deducted from client accounts. There are some legacy clients of Adviser that are invoiced and pay separately. Adviser believes that its fees are competitive with fees charged by other investment advisers for comparable services, but comparable services may be available from other sources for lower fees than those charged by Adviser. 17  Fee Billing Investment management fees are billed quarterly, at the beginning of the quarter based on the total market value of the account as shown on the Firm’s provided portfolio statement on the last business day of the month. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. There are some legacy clients of Adviser that are invoiced and pay separately. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The clients of Rama Financial will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Rama Financial’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Rama Financial’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These 18  fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. 19  Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients Description The Adviser provides services to institutions, individuals, high net worth individuals, pension and profit- sharing plans, trusts, estates or charitable organizations and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser generally requires that the client represents and warrants that the value of their account initially is at least $250,000. At the Adviser’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis 20  Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. 21  Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and 22  past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly 23  competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. 24  Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and 25  unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public 26  information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. 27  Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, 28  which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher 29  risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. 30  Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. 31  Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - 32  Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI 33  technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Rama Financial. Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 34  6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Rama Financial and its associated persons do not have any other financial industry activities or affiliations. 35  Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. 36  As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. 37  Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow 38  the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) 39  Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services 40  may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost 41  the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. 42  Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. 43  According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At 44  the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional 45  information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Item Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. 46  Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake 47  minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. 48  Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 49 

Item 1 – Cover Sheet Sand Creek Investment Partners Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) P.O. Box 2240 Bend, OR 97709 (541) 330-5508 www.sandcreekinvestmentpartners.com March 31, 2026 This brochure provides information about the qualifications and business practices of Sand Creek Investment Partners, Inc. If you have any questions about the contents of this brochure, please contact us at (541) 330-5508, or by email at wendiehohman@sandcreekinvestmentpartners.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this Item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................4 Item 4 – Advisory Business ........................................................................................................................................5 Item 5 – Fees and Compensation .............................................................................................................................. 17 Item 6 – Performance Fees ....................................................................................................................................... 19 Item 7 – Types of Clients ......................................................................................................................................... 20 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................................. 20 Item 9 – Disciplinary Information ............................................................................................................................ 35 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................ 35 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................... 37 Item 12 – Brokerage Practices .................................................................................................................................. 38 Item 13 – Review of Accounts ................................................................................................................................. 43 Item 14 – Client Referrals and Other Compensation ............................................................................................... 45 Item 15 - Custody ..................................................................................................................................................... 46 Item 16 – Investment Discretion .............................................................................................................................. 47 Item 17 – Voting Client Securities ........................................................................................................................... 48 Item 18 – Financial Information ............................................................................................................................... 49 4  Item 4 – Advisory Business Description of Firm Sand Creek Investment Partners, Inc. is a dba of the registered entity Integrated Advisors Network LLC, collectively hereinafter “the Adviser”, “Associate(s)” or “Sand Creek”. Integrated Advisors Network, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. Sand Creek is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Bill Berner and Wendie Hohman are Investment Adviser Representatives (“IARs”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a 5  percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is compensated creates conflicts with your interests, so we operate under a special rule that requires us to act 7  in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: 8  - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) 9  Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third-Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) 10  Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning IAR may provide ongoing investment-related guidance and general financial discussions as part of the advisory relationship. These discussions may include topics such as retirement considerations, cash flow awareness, education funding concepts, or tax considerations as they relate to investment decisions. Such guidance is provided in connection with investment management services and does not constitute a separate or comprehensive financial planning engagement. Other IARs of Integrated may offer financial planning. Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions 13  and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Educational Seminars & Workshop Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) 14  • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. 15  Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 16  Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Sand Creek’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management The Adviser bases its fees on a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the Client is at the Client’s discretion. The Client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance. The investment management fees are negotiable at the sole discretion of the Adviser and fees for comparable services may be available from other sources. Sand Creek’s Client management fees range from 0.05% - 1.15%. The exact fee is based on the strategy(ies) the Client of the IAR selects. At the sole discretion of the Adviser, fees are negotiable for the different program service levels and lower fees may be charged to Clients affiliated with the Adviser. In addition, the Adviser may have arrangements in place with other management personnel and affiliates through which profits are split per agreed upon terms. Fee Billing Investment management fees are billed quarterly, in advance. For advance fee billing accounts, we invoice you - the client - before the three-month billing period has begun, based on the asset value of the client account on the last day of the previous quarter. Payment in full is expected upon invoice presentation. Fees are deducted from the Client account to facilitate billing as authorized by the investment management agreement. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they 17  may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The clients of Sand Creek will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Sand Creek’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Sand Creek’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the 18  market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. 19  Item 7 – Types of Clients Description The Adviser provides services to individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates, or charitable organizations, and corporations or business entities. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser generally requires that the Client represents and warrants that the value of their account initially is at least $50,000. At the Adviser’s discretion, we may accept Clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all 20  environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. The Adviser offers several investment models described below: Conservative Compounding Growth These portfolios will usually own a combination of equities, fixed income, and cash. On occasion they may own other asset classes. Assets will tend to be owned as ETFs and mutual funds. The maximum equity exposure has an 21  approximate guideline of 60 % of the portfolio value. During certain periods these portfolios could experience high turnover as a result of risk-management strategies. This will result in realized capital gains & losses. The goal is to provide lower volatility portfolios (average beta below the S&P 500) that exhibit some stability, some current income, and, over time, a return that exceeds inflation. These portfolios will be guided by a model account that is an actual family portfolio. This portfolio is often used in combination with other portfolios that utilize different investment strategies and goals. Diversified Growth This portfolio strategy has two primary objectives – minimize portfolio losses on a realized basis and grow the value of the portfolios, using a variety of technical indicators and strategies. The assets owned will be primarily ETF’s and common stocks. Other assets may be occasionally owned. It is likely there may be considerable turnover, and numerous short term realized gains and losses. For tax purposes, a tax-deferred account could be beneficial. Portfolios will range from fully-invested in equities to very large percentages of US Treasury bills and cash, depending on the investment environment, and the opportunities and risks offered by the markets. The strategy utilizes a variety of technical identifiers that suggest a positive risk/reward opportunity that could occur in the near future. The portfolio employs active risk-management. The portfolios will be guided by a model account that is an actual family portfolio. This portfolio is often used in combination with other portfolios that utilize different investment strategies and goals. Long Term Growth These portfolios are usually fully-invested in equities, but may, from time to time, go to “cash”, T-Bills, or other alternatives to equities/stocks. The portfolios will primarily own ETF’s (Exchange Traded Funds), which mostly will be invested in US common stocks, but occasionally in foreign stocks, fixed income, or other alternatives. The portfolios are monitored regularly, and reviewed monthly or quarterly for re-balancing, which may or may not result in portfolio changes. The LTG portfolios are guided by a model portfolio that is an actual family portfolio. LTG portfolios are often used in combination with other portfolios that utilize different investment goals & strategies. Long Term Growth – SRI/ESG These portfolios have a long-term growth objective, with little or no market timing involved. They are comprised of ETFs and mutual funds; whose purpose is to offer the Client(s) a venue and placeholder to meet their desires to have socially responsible investments, of which may be a combination of environmental, social and governance business models. This model focuses on carefully selected holdings that have been through a variety of ESG screens and scoring based on ESG values aggregated held away data. The portfolios may have the opportunity to participate in the long term up trends of equity markets. The assets owned reflect the wishes of the Clients and the guidance of Sand Creek partners. These portfolios are reviewed every six months, or if major events occur in the Client's situation or the financial markets, or companies held within the ETFs or mutual funds have fallen out of favor within the ESG scoring parameters. They are then re-balanced if appropriate. While these portfolios are monitored daily, the portfolios have a long-term perspective. Because of the history of financial markets, Clients are encouraged to build an "investment cash reserve fund" separate from the equity portfolio in order to take advantage of the inevitable bear markets that occur, and often provide excellent investment opportunities when many investors are in panic. These portfolios are constructed based on each Client's wishes but are guided by similar portfolios for family members. Pure Fixed Income These portfolios may own fixed income assets: US Treasury bonds, notes, and bills, foreign sovereign bonds, US agency bonds, municipal bonds, corporate bonds, certificates of deposit, preferred stocks, money market funds, TIPS, zero coupon bonds, and other assets considered to be fixed income in nature. Portfolios may own these assets individually, in mutual funds, in ETFs, closed-end funds, or other vehicles that own fixed income assets. This 22  strategy tends toward a conservative approach. The primary goal is preservation of capital, followed by current cash flow appropriate to the Client's risk tolerance and our outlook for that particular fixed income sector. A sub-set of this category would be an "investment cash reserve fund", which is similar, but usually owns shorter duration/maturities and will tend toward higher quality. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. 23  Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. 24  Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes 25  in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar 26  risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. 27  Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. 28  and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose 29  their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. 30  Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain 31  circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types 32  of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. 33  Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory 34  requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Sand Creek. Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 35  7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client 36  need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. 37  This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. 38  While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access 39  to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, 40  and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most 41  favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products 42  and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's 43  financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. 44  As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. 45  Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client directed transfers between accounts held in the client’s name).However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required 46  documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also 47  amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform 48  to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 49 

Item 1 – Cover Sheet Sawyer Capital Investment Advisors Form ADV Part 2A – Firm Brochure 2231 Leyden St. Denver, CO 80207 (720) 231-4010 www.sawyercia.com March 31, 2026 This brochure provides information about the qualifications and business practices of Sawyer Capital Investment Advisors. If you have any questions about the contents of this brochure, please contact us at (720) 231-4010. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this Item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................4 Item 4 – Advisory Business ........................................................................................................................................5 Item 5 – Fees and Compensation ................................................................................................................................5 Item 6 – Performance Fees ....................................................................................................................................... 19 Item 7 – Types of Clients ......................................................................................................................................... 20 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................................. 20 Item 9 – Disciplinary Information ............................................................................................................................ 34 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................ 34 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................... 36 Item 12 – Brokerage Practices .................................................................................................................................. 37 Item 13 – Review of Accounts ................................................................................................................................. 42 Item 14 – Client Referrals and Other Compensation ............................................................................................... 44 Item 15 - Custody ..................................................................................................................................................... 45 Item 16 – Investment Discretion .............................................................................................................................. 46 Item 17 – Voting Client Securities ........................................................................................................................... 47 Item 18 – Financial Information ............................................................................................................................... 48 4  Item 4 – Advisory Business Description of Firm Sawyer Capital Investment Advisors is a dba of the registered entity Integrated Advisors Network LLC, collectively hereinafter “the Adviser”, “Associate” or “Sawyer Capital”. Integrated Advisors Network, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. Sawyer Capital is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Don Sawyer an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a 5  percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is 7  compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should 9  consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third-Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial 10  practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Sawyer Capital through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Sawyer Capital may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. 13  There is an inherent conflict of interest for Sawyer Capital whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Sawyer Capital or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of Sawyer Capital. Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to effect the transaction through Integrated, its Adviser Representatives, Associates, or any other third party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and 14  objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee 15  that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Sawyer Capital’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) 16  Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management The Adviser bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected quarterly in advance. The investment management fees are negotiable at the sole discretion of the Adviser and fees for comparable services may be available from other sources. Fee Schedule Annualized Investment Management Fees Incremental Account Value To Annual Percentage Fee Incremental Account Value From $0 $1,000,001 $1,000,000 Over 1.50% 0.90% If the portfolio management agreement is executed at any time other than the first day of a calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which you are a client. Our advisory fee is negotiable, depending on individual client circumstances. At our discretion, we may combine the account values of family members living in the same household to determine the applicable advisory fee. For example, we may combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts. Combining account values may increase the asset total, which may result in your paying a reduced advisory fee based on the available breakpoints in our fee schedule stated above. Financial Planning Fees We may charge a fixed fee for financial planning services, which generally ranges between $1500 - $3000. The fee is negotiable depending upon the complexity and scope of the plan, your financial situation, and your objectives. We do not require you to pay fees six or more months in advance and in excess of $500. Should the engagement last longer than six months between acceptance of financial planning agreement and delivery of the financial plan, any prepaid unearned fees will be promptly returned to you less a pro rata charge for bona fide financial planning services rendered to date. At our discretion, we may offset our financial planning fees to the extent you implement the financial plan through our Portfolio Management Service. Fee Billing Investment management fees will be billed quarterly in advance, based on an average daily balance. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when 17  authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The clients of Sawyer Capital will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Sawyer Capital’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Sawyer Capital’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. 18  Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both 19  performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients Description The Adviser provides services to individuals and high net worth individuals. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums The Adviser in general, does not require a minimum dollar amount to open and maintain an advisory account; however, we have the right to terminate your account if it falls below a minimum size which, in our sole opinion, is too small to manage effectively. Some advisory groups of Integrated have minimum size account. We may also combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts to meet the stated minimum. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. 20  ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. 21  Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any 22  investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, 23  credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. 24  Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. 25  Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much 26  you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to 27  buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock 28  dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. 29  Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. 30  Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. 31  The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical 32  goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the 33  suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Sawyer Capital. Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. 34  Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Sawyer Capital and its associated persons do not have any other financial industry activities or affiliations. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates 35  communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. 36  Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody 37  Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our 38  clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. 39  Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. 40  Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. 41  Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a 42  marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from 43  Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. 44  Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client-directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's 45  conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” 46  as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. 47  While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 48 

Item 1 – Cover Sheet Select Wealth Advisers Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) Nevada Office 2200 Paseo Verde Pkwy STE 210 Henderson, NV 89052 Memphis Office 6075 Poplar Ave. STE 406 Memphis, TN 38119 (702) 888-3280 www.selectwealthadvisers.com March 31, 2026 This brochure provides information about the qualifications and business practices of Select Wealth Advisers (“SWA”). If you have any questions about the contents of this brochure, please contact us at: (702) 888-3280 or by email at: mhorst@swadvisers.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this Item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet................................................................................................................................... 1 Item 2 – Material Changes .......................................................................................................................... 2 Item 3 – Table of Contents .......................................................................................................................... 4 Item 4 – Advisory Business ........................................................................................................................ 5 Item 5 – Fees and Compensation .............................................................................................................. 17 Item 6 – Performance Fees ....................................................................................................................... 21 Item 7 – Types of Clients .......................................................................................................................... 22 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................. 22 Item 9 – Disciplinary Information ............................................................................................................ 35 Item 10 – Other Financial Industry Activities and Affiliations ................................................................ 36 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........... 38 Item 12 – Brokerage Practices .................................................................................................................. 40 Item 13 – Review of Accounts .................................................................................................................. 40 Item 14 – Client Referrals and Other Compensation ................................................................................ 47 Item 15 - Custody ...................................................................................................................................... 48 Item 16 – Investment Discretion ............................................................................................................... 49 Item 17 – Voting Client Securities............................................................................................................ 50 Item 18 – Financial Information ............................................................................................................... 51 4  Item 4 – Advisory Business Description of Firm Select Wealth Advisers is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter “Adviser”, “Associate” or “SWA”. Integrated Advisors Network, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC-registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. SWA is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Aaron Blaine, Jim Burdett, Mitchell Horst and Scott Lipka are Investment Adviser Representatives (“IARs”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a 5  percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in 6  selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: 7  Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: If you are interested in investing only in mutual funds, you should understand the cost - 8  structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) 9  Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third-Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) 10  Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning SWA through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. SWA may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. 13  There is an inherent conflict of interest for SWA whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. SWA or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated do not make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of SWA. Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Educational Seminars & Workshop Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third 14  party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. 15  Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. 16  Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of SWA’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management The Adviser bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance; therefore, at termination, any unearned fees as determined on a pro-rata basis for the portion of the quarter completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Adviser, and fees for comparable services may be available from other sources. 17  FEE SCHEDULE Incremental Account Value From Annualized Investment Management Fees Incremental Account Value To Annual Percentage Fee $0 $249,999 1.75% $250,000 $499,999 1.50% $500,000 $999,999 1.25% $1,000,000 $1,499,999 1.00% $1,500,000 0.90% $1,999,999 Over $2,000,000 Negotiable Annualized Financial Planning Fees with Managed Portfolio Incremental Account Value From Incremental Account Value To Annual Percentage Fee $0 $499,999 0.15% $500,000 $999,999 0.10% Over $1,000,000 No Cost Annualized Financial Planning Fees without Managed Portfolio Plan Construction $1,500.00 Annual Maintenance $700 ($175 drafted quarterly) Strategy Planning $125/hour Financial Planning and Consulting Fees for Financial Planning and Consulting services can be paid through a variety of options determined by you and your Financial Professional. The fee arrangement should be expressed on the appropriate SWA Agreement. The fee options include the following: Flat Fee Agreement The fee will vary depending on a variety of factors, depending on the scope of services provided, complexity of the process undertaken, the types of issues addressed and the frequency of services. Flat fees charged for financial planning services generally do not exceed $25,000 for individuals. Frequency of payment can be one-time, installment or ongoing at a frequency agreed upon by you and your Financial Professional. Hourly Fee Agreement Financial Professionals are generally not allowed to charge more than $500 on an hourly basis. Asset Based Fee Agreement Investment Consulting services provided based on assets held outside of SWA fall under an Asset Based Fee Agreement. The fee for such services will be a percentage of all assets being managed by the Financial Professional. Financial Planning fees described above do not include the fees you will incur for other professionals (i.e. personal attorney, independent Investment Adviser, or accountant) in connection with the financial planning process. In some 18  instances, fees higher than those stated above will be charged if the scope of the project agreed upon warrants a higher fee. All fees are negotiable and are agreed upon prior to entering into a contract. When the contracted services include providing a physical or electronic document, you will generally receive your financial plan within 90 days of entering into a financial planning contract, provided that all information needed to prepare the Financial Plan has been promptly provided by you. Fees for ongoing financial planning services are due in accordance with the timeframe agreed upon between you and your Financial Professional. The exact fee you will be charged is contingent upon the nature and complexity of your overall financial circumstances. The contract will automatically renew on an annual basis, unless agreed upon to be a one-time service. The investment advisory fee will be divided and billed on a quarterly basis. You and your Financial Professional have the option to choose to have a one-time fee instead of the above billing options. Fees are charged in advance or in arrears depending on the specific arrangement. The contract will automatically renew on an annual basis unless agreed upon to be a one-time fee. Certain charges are imposed by third parties other than SWA in connection with investments recommended through consulting arrangements, including but not limited to, mutual fund and custodial fees. Consulting fees charged by SWA are separate and distinct from the fees and expenses charged by investment company securities that are recommended to you. A description of these fees and expenses are available in each investment company product prospectus. Financial Professionals have the option to waive agreed upon financial planning or consulting fees and expenses if you purchase products or enter into agreements for other services with the Financial Professional. You and the Financial Professional preparing the financial plan or providing the consultation services will determine the exact fee and the manner in which the fee is to be paid. Financial Professionals negotiate fees with each of their clients based on the complexity of that client’s personal circumstances, financial situation and the services that will be provided, the scope of the engagement, the client’s income, the experience and standard fees charged by the Financial Professional providing the services, and the nature and total dollar asset value of the asset upon which services will be provided. In addition, fees may be negotiated based on whether or not the client has assets under management with the Financial Professional. A conflict could arise if ongoing compensation paid for services based on assets under management surpass the negotiated or waived financial planning or consulting services fee. Fee Billing Investment management fees will be billed quarterly in advance. For advance fee billing accounts, we invoice you before the three-month billing period has begun, based on the asset value of your account on the last day of the previous quarter. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they 19  may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The clients of SWA will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. SWA’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that SWA’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the 20  market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. 21  Item 7 – Types of Clients Description The Adviser provides services to individuals, high net worth individuals, trusts, estates, or charitable organizations, banking or thrift institutions, state or municipal government entities, pension and profit-sharing plans, and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums SWA typically imposes a minimum investment amount of $25,000. SWA will accept accounts with less than $25,000 in assets if SWA believes that, based on information provided by you to your Financial Professional, investing a lower amount is appropriate for you and is acceptable to the program sponsor. At the Advisor’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the 22  environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial 23  circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, 24  and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. 25  Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations 26  in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative 27  instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. 28  Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). 29  Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. 30  Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term 31  because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. 32  Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. 33  - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not 34  always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. 35  On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Our Firm offers services through our network of investment advisor representatives (“Investment Adviser Representatives” or “IARs”). IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the businesses are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the following Advisor Representatives of: Select Wealth Advisers. Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. 36  Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. Registered Representative of Broker-Dealer Integrated is not registered and does not intend to register as a broker-dealer. Still, in connection with their approved outside business activities, some Associates are Registered Representatives (“RRs”) of non-affiliated broker- dealers, Members of FINRA/SIPC. Associates with these unaffiliated broker-dealers can provide brokerage services as an RR of the unaffiliated broker-dealer firm. When acting in the capacity of an RR, the Associates will sell, for commissions, general securities products and will receive commission-based compensation in connection with the purchase and sale of such securities, including 12b-1 fees for the sale of investment company products. If your Adviser Representative offers brokerage products as an RR through their unaffiliated broker-dealer, they are not acting in a brokerage capacity or on behalf of Integrated concerning the services provided under our Agreement(s). Integrated is not involved in the transaction and receives no compensation for the Associate's outside business activity. Associates who provide brokerage services through unaffiliated broker-dealers are independent contractors of such companies. Any compensation earned by these individuals in their capacities as RRs is separate, in addition to, and not related to our advisory fees or Agreement to provide advisory services. Clients are under no obligation to use the firm's Associates’ services in this different capacity as broker-dealer employees. Insurance Services SWA and/or certain associated persons of SWA may sell insurance products to advisory clients. Some Associates are licensed as independent insurance agents through non-affiliated insurance companies offering fixed, fixed index, 37  variable annuities, life, or long-term care universal life or other insurance products, and insurance services clients may decide to use Integrated for financial planning or investment advisory services. In these capacities, Integrated Adviser Representatives can recommend to firm clients and receive separate, yet customary, commission compensation, including bonuses and trail commissions, resulting from the purchases and sales of these products from the insurance agencies with whom they are presently or with whom they may become appointed in the future in addition to their compensation from Integrated. Such commissions and advisory fees are separate from the firm's advisory fees and Agreements, and clients are under no obligation, contractually or otherwise, to purchase insurance products or receive investment advice through insurance-licensed Associates in their capacities as insurance agents and/or Integrated Adviser Representatives. Pooled Investment Vehicles Certain investment adviser representatives of Integrated are engaged in business activities related to the sponsorship, management, or sale of pooled investment vehicles. In these capacities, the advisor may serve as the investment manager, general partner, managing member or in a similar role for the pooled investment vehicle. As a result, the representative may receive compensation separate from advisory fees or other economic benefits associated with this activity. This creates a conflict of interest because the Adviser has an incentive to recommend this investment to advisory clients rather than other investments available. To mitigate this conflict, Integrated requires that all investment recommendations be made in the client’s best interest and maintains policies and procedures designed to monitor and mitigate conflicts associated with outside business activities. Additional information regarding custody associated with pooled investment vehicles can be found in Item 15 – Custody of this Brochure. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the 38  Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. 39  Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment programs, and electronic communication delivery capabilities, 40  • • • • • financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • 41  Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, 42  rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) 43  Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) 44  Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. 45  Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. 46  Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Promoter Referrals The Advisor has entered into agreements where it solicits clients and third-party investment advisers refers clients. The Advisor pays for these referrals. The Advisor is required to present a disclosure to all prospects and clients which details the compensation to the third-party and other general terms of the relationship between the third-party and the Advisor. This disclosure is provided by either the third-party or the Advisor. The agreement between the Advisor and the third-party adviser(s) may be terminated by either party’s written notice. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated 47  addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, 48  3. the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. 49  Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. 50  Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 51 

Item 1 – Cover Sheet SF – IAN Firm ADV Part 2A- Firm Brochure (CRD #171991 / SEC #801-96203) Integrated Advisors Network, LLC 304 4th Street Sausalito, CA 94965 (415) 999-2162 www.SF-ian.com March 31, 2026 This brochure provides information about the qualifications and business practices of SF-IAN. If you have any questions about the contents of this brochure, please contact us at: (415) 999-2162 or the Chief Compliance Officer at (855) 729-4222. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Adviser is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this Item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet................................................................................................................................... 1 Item 2 – Material Changes .......................................................................................................................... 2 Item 3 – Table of Contents .......................................................................................................................... 4 Item 4 – Advisory Business ........................................................................................................................ 5 Item 5 – Fees and Compensation .............................................................................................................. 16 Item 6 – Performance Fees ....................................................................................................................... 17 Item 7 – Types of Clients .......................................................................................................................... 19 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................. 19 Item 9 – Disciplinary Information ............................................................................................................ 33 Item 10 – Other Financial Industry Activities and Affiliations ................................................................ 33 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........... 35 Item 12 – Brokerage Practices .................................................................................................................. 36 Item 13 – Review of Accounts .................................................................................................................. 41 Item 14 – Client Referrals and Other Compensation ................................................................................ 43 Item 15 - Custody ...................................................................................................................................... 44 Item 16 – Item Discretion ......................................................................................................................... 45 Item 17 – Voting Client Securities............................................................................................................ 47 Item 18 – Financial Information ............................................................................................................... 47 4  Item 4 – Advisory Business Description of Firm SF – IAN does business under the registered entity Integrated Advisors Network, LLC, collectively hereinafter “the Adviser”, “Associate” or SF-IAN. Integrated Advisors, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. SF-IAN is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Bruce Woodward is an Investment Adviser Representative(s) (“IAR(s)”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a 5  percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is 7  compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 72. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should 9  consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third-Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial 10  practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to effect the transaction through Integrated, its Adviser Representatives, Associates, or any other third party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest 13  can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. 14  Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. 15  Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of SF-IAN’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Fees are negotiable and may vary but generally will be based on an annual percentage rate of 1% of assets under management. Fees are payable quarterly at the beginning of each calendar quarter based on the market value of the assets under management at the close of the prior quarter. Fees on additions or withdrawals are pro-rated. A client may terminate an investment advisory agreement with five (5) business days advance written notice. On termination, clients may receive a refund of advisory fees on a pro-rated basis. Adviser prefers to have management fees deducted from client accounts. There are some legacy clients of Adviser that are invoiced and pay separately. Adviser believes that its fees are competitive with fees charged by other investment advisers for comparable services, but comparable services may be available from other sources for lower fees than those charged by Adviser. Fee Billing Investment management fees are billed quarterly in advance based on the total market value of the account as shown on the Firm’s provided portfolio statement on the last business day of the month. Account values are based upon pricing information supplied by the client’s 3rd party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. There are some legacy clients of Adviser that are invoiced and pay separately. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) 16  The client’s custodian will deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The clients of SF - IAN will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. SF – IAN’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that SF – IAN’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. 17  Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both 18  performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients Description The Adviser provides services to institutions, individuals, high net worth individuals, pension and profit- sharing plans, trusts, estates or charitable organizations and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser generally requires that the client represents and warrants that the value of their account initially is at least $250,000. At the Adviser’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. 19  ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. 20  Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any 21  investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, 22  credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. 23  Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. 24  Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much 25  you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to 26  buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock 27  dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. 28  Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. 29  Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. 30  The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical 31  goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the 32  suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of SF-IAN. Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. 33  Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. SF-IAN and its associated persons do not have any other financial industry activities or affiliations. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates 34  communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. 35  Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody 36  Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our 37  clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. 38  Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. 39  Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. 40  Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a 41  marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from 42  Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. 43  Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Insurance Referral and Compensation The Adviser may refer clients to unaffiliated insurance companies or insurance professionals to obtain insurance products. In connection with these referrals, the referring Adviser may receive referral fees or other forms of compensation from the insurance company or insurance provider. The referring Adviser is not licensed to sell insurance products and does not act as an insurance agent or broker. The Adviser’s role is limited to making the referral. Any insurance products are offered, sold, and administered solely by the insurance company or its licensed representatives, and not by the Adviser in their advisory capacity. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. The Adviser does not supervise, manage, or guarantee any insurance products or services offered by third-party insurance providers. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client-directed transfers between accounts held in the client’s name).. However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited 44  authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. 45  For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. 46  Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- 47  regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 48 

Item 1 – Cover Sheet Shields Capital Advisors Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 22 Ashcroft Ct. Fox River Grove, IL 60021 (312) 953-0115 www.shieldscap.com March 31, 2026 This brochure provides information about the qualifications and business practices of Shields Capital Advisors, Inc. If you have any questions about the contents of this brochure, please contact us by telephone at (312) 953- 0115, or by email at bill@shieldscap.com Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfo.sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this Item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ..................................................................................................................................................1 Item 2 – Material Changes .........................................................................................................................................2 Item 3 – Table of Contents .........................................................................................................................................4 Item 4 – Advisory Business ........................................................................................................................................5 Item 5 – Fees and Compensation .............................................................................................................................. 17 Item 6 – Performance Fees ....................................................................................................................................... 20 Item 7 – Types of Clients ......................................................................................................................................... 20 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................................. 20 Item 9 – Disciplinary Action .................................................................................................................................... 34 Item 10 – Other Financial Industry Activities and Affiliations ................................................................................ 34 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................... 36 Item 12 – Brokerage Practices .................................................................................................................................. 38 Item 13 – Review of Accounts ................................................................................................................................. 43 Item 14 – Client Referrals and Other Compensation ............................................................................................... 44 Item 15 - Custody ..................................................................................................................................................... 46 Item 16 – Investment Discretion .............................................................................................................................. 47 Item 17 – Voting Client Securities ........................................................................................................................... 48 Item 18 – Financial Information ............................................................................................................................... 49 4  Item 4 – Advisory Business Description of Firm Shields Capital Advisors Inc is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter “the Adviser”, “Associate” “Shields Capital Advisors” or “Shields”. Integrated Advisors Network, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC-registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. Shields Capital is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Bill Yocius and Dwight Ower are Investment Adviser Representatives (“IARs”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a 5  percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is 7  compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should 9  consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third-Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial 10  practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Shields Capital through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Shields Capital may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. 13  There is an inherent conflict of interest for Shields Capital whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Shields Capital or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of Shields Capital. Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. 14  Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. 15  Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. 16  Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Shields Capital’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management The Adviser bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance therefore at termination any unearned fees as determined on a pro rata basis for the portion of the month completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Adviser and fees for comparable services may be available from other sources. Total Assets Under Management Annual Fees $0 - $250,000 1.00% 0.50% $250,001 – And Up Pension Consulting Fees Shields Capital Advisors generally charges as fixed project-based fee to provide clients with retirement plan consulting services. Each engagement is individually negotiated and tailored to accommodate the needs of the individual plan sponsor, as memorialized in the Agreement. These fees vary, based on the scope of the services to be rendered. In those situations where Shields Capital Advisors has agreed to manage a plan’s assets. Total Assets Under Management Annual Fee All Assets 0.95% 17  Fee Billing Investment management fees will be billed quarterly in advance. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The clients of Shields Capital Advisors will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Shields’ fees may be higher or lower than other advisory groups at Integrated and there is no representation that Shields fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These 18  fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. 19  Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients Description The Adviser provides services to institutions, individuals, high net worth individuals, pension and profit sharing plans, charitable organizations, and government entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser generally requires that the client represents and warrants that the value of their account initially is at least $100,000. At the Adviser’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis 20  Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively 21  short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. 22  Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. 23  Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly 24  hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil 25  exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. 26  Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some 27  ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, 28  somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and 29  medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management 30  service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections 31  applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. 32  If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape 33  surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Action Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Shields Capital. Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end 34  investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. 35  While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Insurance Services Shields Capital Advisors and/or certain associated persons of Shields Capital Advisors may sell insurance products to advisory clients. Some Associates are licensed as independent insurance agents through non-affiliated insurance companies offering fixed, fixed index, variable annuities, life, or long-term care universal life or other insurance products, and insurance services clients may decide to use Integrated for financial planning or investment advisory services. In these capacities, Integrated Adviser Representatives can recommend to firm clients and receive separate, yet customary, commission compensation, including bonuses and trail commissions, resulting from the purchases and sales of these products from the insurance agencies with whom they are presently or with whom they may become appointed in the future in addition to their compensation from Integrated. Such commissions and advisory fees are separate from the firm's advisory fees and Agreements, and clients are under no obligation, contractually or otherwise, to purchase insurance products or receive investment advice through insurance-licensed Associates in their capacities as insurance agents and/or Integrated Adviser Representatives. Pension Consultation Services Associated persons of Integrated and/or Shields can also act as a pension consultant and from time to time, may offer clients advice or products from those activities and clients should be aware that these services may involve a conflict of interest. Shields Capital Advisors always act in the best interest of the client and clients are in no way required to utilize the services of any representative of Shields in connection with such individual’s activities outside of Shields. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the 36  Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security 37  for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., • • 38  • • • the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. 39  Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. 40  In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and 41  IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests 42  always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. 43  Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. 44  Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. 45  Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw money, securities, or other property from any client custodial account except as authorized in writing by the client and permitted by the qualified custodian (e.g., deduction of advisory fees and, if applicable, client directed transfers between accounts held in the client’s name). However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. 46  Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). 47  Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of 48  these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. 49 

Item 1 – Cover Sheet Sztrom Wealth Management, Inc. (a dba of Integrated Advisors Network, LLC) Form ADV Part 2B Brochure Supplement for Michael Sztrom (CRD #3042821) 16054 Via Galan Rancho Santa Fe, CA 92091 (858) 395-8907 mike@sztromwealth.com March 3, 2026 This Brochure Supplement provides information about Michael Sztrom that supplements the Sztrom Wealth Management, Inc, a dba of Integrated Advisors Network, LLC Form ADV Part 2A Firm Brochure. You should have received a copy of that Brochure. If you have any questions about the contents of this brochure, please contact us at: 858-252-0874 or Danielle L. Tyler, Chief Compliance Officer of Integrated Advisors Network at 855-729- 4222 or compliance@integratedadvisorsnetwork.com. Additional information about Michael Sztrom is available on the United States Securities and Exchange Commission's website at www.adviserinfo.sec.gov. (Click the link, select "Individual," and type in CRD #3042821.) 1  Michael Sztrom Year of Birth: 1954 Item 2 – Educational Background and Business Experience Educational Background Mr. Sztrom has fulfilled Integrated Advisors Network's requirement that its Investment Professionals hold either a Bachelor's degree, further coursework (i.e., an MBA, CFP, CFA, ChFC, JD, CTFA, EA, or CPA), or possess relevant work experience demonstrating their knowledge of and aptitude for, investment management principles. Business Experience: Integrated Advisors Network, LLC, Investment Adviser Representative Sztrom Capital Management, LLC, President Sztrom Wealth Management, LLC, Financial Planning Consultant UBS Financial Services, Senior Vice President Deutsche Bank, Senior Vice President • 03/2018 – Present • 06/2016 – Present • 08/2015 – 03/2018 • 11/2010 – 08/2015 • 04/2007 – 11/2010 Item 3 – Disciplinary Information Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil, or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement, or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair, or unethical practices. Mr. Sztrom has legal or disciplinary events material to a client's or prospective client's evaluation of this advisory business related to knowing an associate conducted securities business without appropriate licensure. For further details, please visit the United States Securities and Exchange Commission's ("SEC") website at www.adviserinfo.sec.gov for a free and simple search tool to research Integrated Advisors Network and its financial professionals in consideration of your evaluation. Item 4 - Other Business Activities Mr. Sztrom is an Advisor Representative of Integrated who dedicates his time to this activity during trading hours. Outside of his activities at Integrated, Mr. Sztrom does not have any other business activities. Item 5 - Additional Compensation Outside of the items listed herein, Mr. Sztrom does not receive any additional economic benefit from any person, company, or organization in exchange for providing clients advisory services through SWM. Please visit the United States Securities and Exchange Commission's website at www.adviserinfo.sec.gov for a free and simple search tool to research his background by searching with his full name or individual CRD #3042821. Item 6 - Supervision Mr. Sztrom is directly supervised by Michael A. Young (T: 855-729-4222). Mr. Young monitors Mr. Sztrom’s workflow and adherence to requirements via remote communications and the Adviser's firm and client relationship management systems. SWM’s policy requires the Firm and all Associates to conduct its affairs in strict compliance with the letter and spirit of the law and adhere to the highest principles of business ethics. Associates are required to abide fully by all applicable federal and state regulations and the firm's guiding principles as outlined in Integrated Advisors Network’s written supervisory Policies & Procedures Manual and Code of Ethics ("COE" or the "Code"), including any updates to them. The Code requires all Associates to exercise a fiduciary duty to clients by acting in each 2  client's best interest and placing client interests first and foremost. Associates must attest no less than annually to their compliance with and understanding of the above matters, including confirmation and acknowledgment by every Advisor Representative of the firm's expectations regarding their conduct, given the required duties, responsibilities, and principles. Mr. Sztrom strives to always act in clients' best interests and adhere to all required regulations regarding the activities of a registered Investment Advisor Representative. 3 

Item 1 – Cover Sheet Vineyard Global Advisors, LLC Form ADV Part 2A - Firm Brochure (CRD #171991 / SEC #801-96203) 9800 Mt. Pyramid Ct. Suite 400 Englewood, CO 80112 Telephone: 303-814-6818 www.vineyardglobaladvisors.com March 31, 2026 This Form ADV Part 2A Disclosure Brochure ("Brochure") provides information about the qualifications and business practices of Vineyard Global Advisors, LLC, a DBA of Integrated Advisors Network, an investment adviser registered with the United States Securities and Exchange Commission ("SEC"). If you have questions about this Brochure's contents, please contact Tom R. Samuelson, Chief Investment Officer of Vineyard Global Advisors, LLC, at 720-470-3252 or tom@vineyardglobaladvisors.com or Danielle L. Tyler, Chief Compliance Officer of Integrated Advisors Network at 855-729-4222 or compliance@integratedadvisorsnetwork.com. The information in this Brochure has not been approved or verified by the SEC or any state securities authority. Nothing in this document is to be construed as a recommendation or an endorsement by the SEC or any state securities authority or an offer of securities; refer to the actual investment offering and related legal documentation for complete disclosures. Please note that registration as an investment adviser does not imply a certain level of skill or training. An adviser's written and oral communications provide information to determine whether to retain the adviser's services. This Brochure is on file with the appropriate regulatory authorities as Federal and state regulations require. Additional information about Vineyard Global Advisors, LLC and Integrated Advisors Network, LLC is also available on the SEC's website at www.adviserinfo.sec.gov. (Click on the link, select "Investment Adviser- Firm," and type in our firm name or CRD #171991. Results will provide you with all firm disclosure brochures.) 1  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Frm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet.............................................................................................................................. 1 Item 2 – Material Changes ..................................................................................................................... 2 Item 3 – Table of Contents ..................................................................................................................... 4 Item 4 – Advisory Business.................................................................................................................... 5 Item 5 – Fees and Compensation .......................................................................................................... 17 Item 6 – Performance Fees ................................................................................................................... 21 Item 7 – Types of Clients ..................................................................................................................... 21 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................ 21 Item 9 – Disciplinary Information ........................................................................................................ 37 Item 10 – Other Financial Industry Activities and Affiliations .............................................................. 38 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........... 40 Item 12 – Brokerage Practices .............................................................................................................. 41 Item 13 – Review of Accounts ............................................................................................................. 46 Item 14 – Client Referrals and Other Compensation ............................................................................. 48 Item 15 - Custody ................................................................................................................................ 49 Item 16 – Investment Discretion .......................................................................................................... 50 Item 17 – Voting Client Securities ....................................................................................................... 51 Item 18 – Financial Information ........................................................................................................... 52 4  Item 4 – Advisory Business Descsription of Firm Vineyard Global Advisors LLC is a DBA of Integrated Advisors Network, an investment advisor registered with the Securities and Exchange Commission ("SEC") pursuant to the Investment Advisers Act of 1940 (the "Advisers Act") (collectively and hereafter referred to as "VGA" or "the Adviser”). Integrated, organized as a limited liability company in 2014, has been SEC-registered since May 11, 2015. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. VGA is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Tom Samuelson is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in 5  substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management 6  Agreement. If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS"), plan or other report to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement 7  account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). interest. - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: such as employer securities or previously closed funds. Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, - - 8  2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. - You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 73. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other 9  important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third-Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides 10  investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed 11  investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full 12  discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated does not invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning VGA through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs VGA may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. There is an inherent conflict of interest for VGA whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services VGA or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of VGA. 13  Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Educational Seminars & Workshops Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. (See Item 10: Other Financial Industry Activities & Affiliations.) Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or 14  services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. 15  Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program Under our Wrap Fee Program Services, VGA is the Sponsor of the Vineyard Global Advisors Managed Account Program ("VGA MAP" or the “Program”), a bundled asset-based fee Program that differs from a regular advisory services account in that clients receive both investment advisory services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Wrap Fee” or “Program Fee") regardless of the number of trades completed by a client. The assets in each Program are regularly monitored, with investment strategy purchase and sale transactions based on the client's specific needs and investment goals. Program clients will undergo the same collection of client profile information and analysis as indicated in the preceding “Investment Management Services” section and enter into a separate Agreement to participate in the Program that sets forth the terms and conditions of the engagement, describes the scope of the services to be provided, fees to be paid, and type of authority granted to VGA. Final advisory fee structures are documented within the written Agreement. Clients will then invest in the Program by establishing one or more accounts with the Custodian. As the Program's Sponsor and investment manager, VGA receives management fees and a portion of the Wrap Fee related to administrative services the Adviser performs from the payment of the Wrap Fee. Generally, clients participating in this type of Program will pay the Wrap Fee to the Program sponsor quarterly in based on the total portfolio value as of the last business day of the preceding calendar year. With the client’s written permission, this fee payment will be debited from the client’s account by the Custodian. VGA passes on a portion of the Wrap Fee to the broker-dealer partner of the Program for its services, which can include management and custodial fees, the execution of securities brokerage transaction/trading expenses, and reporting and administrative costs) and retains a portion of the Wrap Fee for the advisory services it provides. The overall costs clients will incur if they participate in our Wrap Fee Program can be higher or lower than they could incur by separately purchasing the types of securities available in the Program. Clients should be aware that a conflict of interest exists whenever VGA recommends participating in its Wrap Fee Program. Because the Wrap Fee Program has a higher fee, Advisor Representatives have a slight incentive to offer it over a non-wrap fee program, so they could be financially incentivized to recommend such a service. 16  In addition, VGA will also work with other Advisor Representatives by having their clients participate in the VGA MAP. (Note: Incorporated by reference is the VGA MAP Program WRAP Brochure.) The SEC rules require that a Wrap Fee Brochure be provided to clients before or when entering a Program Agreement. VGA has prepared a Wrap Fee Brochure to satisfy this requirement that provides clients with important information about our Program, including further information about the services and fees the client will pay. Clients are encouraged to carefully review all Program documents and discuss any questions they may have with their Advisor Representative and other professionals prior to Program participation and at any time they may have questions or concerns after Program account establishment. Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of VGA’s Form ADV Part 2A Brochure, the applicable Adviser Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. 17  Regardless of fee negotiation availability, under no circumstances will a client be required to pre-pay a VGA advisory fee more than six months in advance, in excess of $1,200. Investment Management Services Fees For Investment Management Services, VGA will charge from 0.25% - 0.75% of the total assets under management, up to a maximum annual fee of up to 2.95%, based upon a percentage of the market value of the client’s assets under management, calculated and billed consistent with the Adviser’s disclosure documents and each client’s executed Agreement. Each client's executed Agreement will indicate the exact advisory service and strategy(ies) selected, the final advisory fee and the fee-payment arrangement before the delivery of any advisory services commences. (Note: Lower fees for comparable services can sometimes be available from other sources.) Under certain circumstances, all advisory fees are negotiable up to the maximum annual rates listed herein, subject to certain limitations and approval by VGA. The Adviser, in its sole discretion, can charge lesser fees or choose to reduce or waive minimum fees for services based upon specific criteria such as pre-existing client relationships, the number of related investment accounts, inception date, total account assets under management, expected additional assets, anticipated future earning capacity, account composition, and client negotiations, among others. At our discretion, certain employee accounts or for members of a client's family or otherwise can be assessed fees based on the total balance of all accounts. While VGA seeks to facilitate advantageous agreements for clients, to the extent fees are negotiable, some clients can pay higher (more) or lower fees (less) than other clients for services than if they had contracted directly with another provider. According to the selected advisory services, the final fee structures will be reflected in each client's written Agreement. Lower fees for comparable services can sometimes be available from other sources. In all cases, clients are responsible for any tax liabilities that result from any transactions. Fee Calculation Except as otherwise described in this section, Investment Management Services advisory fees are billed quarterly in advance, based on a percentage of assets under management calculated on the average daily balance of the client’s account as of the last day of the preceding quarter. (Note: This means clients will be invoiced for advisory fees due before the next quarter’s billing period begins.) If an Agreement is executed at any time other than the first day of a calendar month/quarter, our fees will apply on a pro-rata basis, which means that the advisory fee is payable in proportion to the number of days in the month/quarter for which you are a client. Assets under management include all U.S. securities, non-U.S. securities, cash and other instruments in a client's account advised by VGA. VGA considers cash to be an asset class. Depending on market conditions, investment advisory strategies often involve moving to cash positions for varying periods. As a result, cash balances are included in the value of the assets under our management that are the basis for charging our advisory fee unless otherwise noted in the Agreement. The advisory fee billed to the cash portion of client accounts will exceed money market yields when rates for such money market funds are lower than the advisory fees charged to the account. Securities without a readily available market price are valued at fair value, as determined in good faith by the Custodian. With respect to client account assets in alternative investments, alternative investment managers and underlying vehicles are responsible for providing the Custodian with an asset's valuation in accordance with applicable laws. 18  Wrap Fee Program Services Fees VGA’s Wrap Fee Program Services fees for the Vineyard Global Advisers Managed Account Program (“VGA MAP” or the “Program”) are asset-based fees that will include investment advisory services fees and the fees for most of the brokerage, custody, clearance, settlement, and other administrative services and transaction costs to the broker-dealer/Custodian with custody of the client’s assets and, therefore, are usually higher than a typical asset- based advisory fee. VGA will receive a portion of the Wrap Fee for its services. Wrap Fees are generally billed quarterly in advance, based on the net asset value of each account at the end of the previous period, including assets invested in cash and cash equivalents, accrued interest, and dividends. (For complete details, refer to the Adviser’s Form ADV Part 2A – Appendix 1 Wrap Fee Brochure and the Wrap Fee Program Agreement.) Fee Billing Clients select their preferred fee billing and payment method in the Investment Management Agreement. As a general practice, advisory fees are directly debited from the client’s custodial account. At the client’s election, fees may alternatively be billed directly to the client. Any billed fees are due in full upon receipt of the invoice. The Adviser will not deduct or debit advisory fees from any client account without the client’s prior written authorization. Clients who wish to have their advisory fees directly debited will authorize VGA in writing to directly deduct advisory fees due from their Custodial account and provide the Custodian with authorization to deduct such fees and instructions to remit them straight to VGA. VGA will calculate the advisory fees due based on the client’s Agreement and send the client an invoice showing the amount of the fee, the value of the assets on which the fee is based, the period covered by the fee, and the specific manner in which the fee was calculated, and the account Custodian will agree to send the client a statement, at least quarterly, indicating all amounts disbursed from their account, including the amount of the advisory fee paid directly to VGA. The account Custodian does not verify the accuracy of the Adviser’s advisory fee calculation. Upon receiving VGA’s instructions, the Custodian will automatically deduct and pay from the client’s account the fee amount due, regardless of the portfolio’s market performance during the preceding quarter. VGA’s account advisory fee will be payable first from free credit balances, money market funds, or cash equivalents, if any, and second from the liquidation of a portion of the client’s securities holdings. Please note that ongoing fees reduce the value of an investment portfolio over time - when our advisory fee is debited from the portfolio's assets, clients have less money invested to generate a return. Clients are encouraged to discuss the impact of fees with their Advisor Representative. When authorized by the client to debit advisory fees from client accounts, VGA is deemed to have custody of client assets to the extent the Adviser is permitted to instruct Custodians to deduct the fees. If clients find any inconsistent information between our invoice and the statement(s) they receive from their Custodian, they should contact us directly. If a client is not receiving statements directly from their Custodian, in addition to promptly advising their Advisor Representative, VGA also recommends they contact their Custodian. VGA urges clients to review any Custodial account statements received promptly upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The following is for disclosure purposes only: Integrated retains other Adviser Representatives who offer fees that can vary from the VGA fees disclosed herein, which fees may be collected in arrears or in advance, as disclosed within each advisory group’s specific brochure. 19  Fee schedules are specific to each Integrated advisory group, and VGA’s clients will not pay or be affected by the fees charged by these Advisor Representative groups. The VGA advisory group may have fees that are higher or lower than these other Integrated advisory groups, and there is no representation that VGA's fees are the lowest available for similar services. Fees Charged to Third Party Advisers VGA receives an annual fee based on the total assets in each third-party adviser's clients' accounts, for which we provide sub-advisory management services. The Adviser is paid the sub-advisory fees quarterly, either in advance or arrears, depending on the arrangement with the third-party adviser. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. 20  Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients The Adviser generally provides investment advice to individuals, pension and profit-sharing plans, trusts, estates, or charitable organizations, corporations or business entities. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser generally requires that the client represents and warrants that the value of their account initially is at least $50,000. At the Adviser’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to 21  the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies Strategies may include long-term purchases, short-term purchases, trading, short sales, margin transactions, and option writing (including covered options, uncovered options or spreading strategies). Other types of investment strategies from which clients can choose include: VGA ETF Advantage Series - The VGA ETF Advantage series is a group of managed asset allocation strategies offered by VGA that utilize exchange-traded funds (“ETFs”) in five custom market models that range from capital preservation (10% equity-90% fixed income) to aggressive growth (90% equity-10% fixed income). The models are offered in both tax-sensitive and qualified versions. The strategies provide exposure to nine different asset classes that include U.S. equities, foreign-developed equities, emerging market equities, fixed income, real estate, master limited partnerships, commodities, alternatives and cash. Broad diversification across these asset classes provides a primary layer of risk management, while additional downside protection is provided by tactical asset class adjustments and the use of opportunistic hedge positions based on input from our macro models. ETFs offer low operating costs, tax efficiency and low minimum investment entry levels, making the ETF Advantage strategy available to lower account sizes 22  (minimum $10,000). VGA Allocation Plus Series - The VGA Allocation Plus series is a group of managed asset allocation strategies we offer that utilize mutual funds and ETFs in five custom market models that range from capital preservation (10% equity-90% fixed income) to aggressive growth (90% equity-10% fixed income). The models are offered in both tax-sensitive and qualified versions. Actively managed mutual funds are selected through proprietary research designed to identify those managers that have been able to consistently offer returns above their respective asset categories (manager "alpha"). In asset categories where little additional alpha can be obtained through active management, that category is sourced with a passive ETF. The strategies provide exposure to nine different asset classes that include U.S. equities, foreign-developed equities, emerging market equities, fixed income, real estate, master limited partnerships, commodities, alternatives and cash. Broad diversification across these asset classes provides a primary layer of risk management, while additional downside protection is provided by tactical asset class adjustments and opportunistic hedge positions based on input from our macro models. Several of the mutual funds require higher minimum initial investment levels, making this strategy available for account sizes of $100,000+. VGA Advantage Plus Series - The VGA Advantage Plus Series is a group of managed asset allocation strategies offered VGA that utilize mutual funds, ETFs and internal proprietary investment strategies in five custom market models that range from capital preservation (10% equity-90% fixed income) to aggressive growth (90% equity-10% fixed income). The Allocation Advantage Plus strategy is offered in a unified managed account (“UMA”) format, which is a sophisticated design that combines multiple investment vehicles into a single portfolio account, maximizing efforts to enhance diversification. The models are offered in both tax-sensitive and qualified versions. The strategy utilizes both VGA-actively managed strategies and mutual funds that have been selected through proprietary research designed to identify managers that have been able to consistently offer returns above their respective asset categories (manager "alpha"). The internal strategies and mutual funds are included in an effort to maximize risk-adjusted returns. In asset categories where active management has provided minimal alpha, that category is sourced with a passive ETF. The strategies provide exposure to nine different asset classes that include U.S. equities, foreign-developed equities, emerging market equities, fixed income, real estate, master limited partnerships, commodities, alternatives and cash. Broad diversification across these asset classes provides a primary layer of risk management, while additional downside protection is provided by tactical asset class adjustments and opportunistic hedge positions based on input from our macro models. Several mutual funds and internal strategies require higher minimum investment levels, making this strategy available for account sizes of $500,000+. VGA R3000 Enhanced Dividend - The VGA R3000 Enhanced Dividend strategy is a proprietary strategy managed by VGA that invests primarily in dividend-paying U.S. stocks that are selected through a proprietary screening process developed to identify companies that may offer above-average total return potential, with a primary focus on income. The strategy may also invest in income-producing American Depository Receipts ("ADRs"), ETFs, and closed-end funds ("CEFs"). The strategy deploys a risk-managed approach whereby equity exposure is reduced when our macro models determine the investment backdrop has deteriorated. Equity exposure can range from between 25% net long (during maximum negative market backdrops) to 125% net long (during maximum positive market backdrops). The minimum account size is $25,000. VGA Enhanced S&P 500 - The VGA Enhanced S&P 500 strategy is a proprietary strategy managed by VGA that invests in S&P 500 stocks that are selected through a proprietary screening process developed to identify companies that may offer above-average total return potential. The strategy deploys a risk-managed approach whereby equity exposure is reduced when our macro models suggest the investment backdrop has deteriorated. Equity exposure can range from -5% net long (during maximum negative market backdrops) to 120% net long (during maximum positive market backdrops). VGA-enhanced S&P 500 seeks to outperform the S&P 500 index with a bias toward downside risk management. The strategy is designed to provide equity market participation during bullish phases as determined by our macro models while attempting to provide downside protection when our macro models suggest the equity market backdrop has deteriorated. The minimum account size is $25,000. VGA Global Fixed Income - The VGA Global Fixed Income strategy is a proprietary fixed-income allocation 23  strategy managed by VGA that invests in fixed-income ETFs, CEFs and mutual funds. The strategy invests across 22 fixed-income categories selected for their diversification attributes. The strategy is offered in both tax-sensitive and qualified versions. Risk management may be further enhanced through the use of ETF hedge positions, which can be included to manage interest rate and credit risk, depending upon input from our macro models. The VGA Global Fixed Income strategies are intended for investors with low-risk tolerance and to provide portfolio diversification benefits when added to higher volatility equity allocations. The minimum account size is $10,000. VGA Dynamic Yield - The VGA Dynamic Yield is an income-focused strategy that invests in U.S. dividend- paying stocks, American Depository Receipts ("ADRs”), CEFs and open-end mutual funds. Its primary objective is to offer risk-managed income sourced through dividends, interest income and royalty payments. It seeks to achieve its objective by investing in a portfolio of approximately 65 positions that offers exposure to all the major, publicly- traded income-producing asset categories. Risk management is achieved through (1) broad diversification across asset classes, (2) dynamic adjustment of the equity and fixed-income portions of the portfolio (based on input from our macro models) and (3) the use of opportunistic ETF hedge positions to further address equity, credit and interest rate risk. The minimum account size is $25,000. VGA Covered Call - VGA Covered Call is a proprietary separately managed account strategy that seeks attractive risk-adjusted returns through the purchase of a diversified equity portfolio and concurrent sale of call options, which may provide partial downside protection plus the potential for auxiliary income generation. The portfolio consists of 16-35 individual covered call positions that are diversified by sector, strike price and expiration date. Individual stocks are systematically selected through proprietary screens and then scored using a multi-factor model that evaluates their attractiveness at the time of purchase. The minimum account size is $150,000. VGA Custom Covered Call - The VGA Custom Covered Call strategy is offered on an account-by-account basis as a way for clients to generate auxiliary income on concentrated equity positions through the sale of call options. First, the client determines a level at which they are indifferent to selling the underlying stock position. Then, VGA deploys an opportunistic covered call writing program around the agreed-upon exit price with an eye towards trading the calls for a profit should the overall stock market or that particular stock decline in value. The minimum account size: $1,000,000. VGA Optimized Equity Alpha - VGA Optimized Equity Alpha is a strategy managed by VGA that invests in U.S.-listed stocks and ETFs, seeking to achieve its objective of long-term capital appreciation by combining a sector rotation strategy and a style preference strategy (growth vs. value). These two different approaches are combined into one strategy due to their diversification benefits. The strategy is designed to provide strong equity market participation during neutral to bullish investment backdrops, as determined by VGA's proprietary macro models, with a focus on capital preservation during bearish investment backdrops. Equity exposure can range from 100% net long during maximum bullish backdrops to 0% during maximum bearish backdrops. The minimum account size is $150,000. VGA Private Client Services ("PCS") - The VGA Private Client Services ("PCS") provides customized portfolio construction solutions to high net-worth clients, generally with a liquid net worth in excess of $1,000,000. Customized portfolio solutions are designed and implemented after consultation with an advisor who seeks to determine the appropriate allocation based on the client's individualized investment objectives and/or financial plan. An open architecture environment is utilized that may invest across a broad array of stocks, bonds, exchange-traded funds, closed and open-end mutual funds, proprietary internal strategies and alternative and structured investment products. VGA PCS is offered in a unified managed account format, which is a sophisticated design that combines multiple investment vehicles into a single portfolio account, maximizing efforts to enhance diversification. The minimum account size: $1,000,000. VGA Risk Managed Income - The VGA Dynamic Yield is an income-focused strategy that invests in U.S. dividend-paying stocks, ADRs), CEFs and open-end mutual funds. Its primary objective is to offer a low- volatility, risk-managed income solution sourced through dividends, interest income and royalty payments. Risk Management is achieved through (1) constraining equity exposure to a maximum of 30% of the overall strategy, (2) dynamic adjustment of the equity and fixed income portions of the portfolio (based on input from our macro models) and (3) the use of opportunistic ETF hedge positions further to address equity, credit 24  and interest rate risk. The minimum account size is $25,000. VGA Quantitative Value - The VGA Quantitative Value is a strategy managed by VGA that invests in a targeted portfolio of approximately 50 top-ranked stocks in the Russell 3000 Value index selected through a proprietary screening process designed to identify companies with above-average total return potential. The screening process seeks to identify companies with a unique blend of value, quality, profitability, growth, and price momentum attributes that have historically been associated with superior stock performance. The strategy is offered in two versions: long-only and hedged. The Long-only version remains at least 80% invested regardless of the market backdrop. The hedged version will scale overall portfolio equity exposure from 0% net long to 100% net long during maximum bearish to maximum bullish market backdrops, respectively. The strategy is rebalanced quarterly, although individual positions may be adjusted opportunistically. The minimum account size is $50,000. VGA Quantitative Growth – VGA Quantitative Growth is a strategy managed by VGA that invests in a targeted portfolio of approximately 50 top-ranked stocks in the Russell 3000 Growth index selected through a proprietary screening process designed to identify companies with above-average total return potential, utilizing a "growth at a reasonable price" or GARP methodology. The screening process seeks to identify companies with a unique blend of earnings growth, earnings momentum, earnings consistency, valuation and price momentum attributes that have historically been associated with superior stock performance. The strategy is offered in two versions: long-only and hedged. The long-only version remains at least 80% invested regardless of the market backdrop. The hedged version will scale overall portfolio equity exposure from 0% net long to 100% net long during maximum bearish to maximum bullish market backdrops, respectively. The strategy is rebalanced quarterly, although individual positions may be adjusted opportunistically. Minimum account size: $50,000. VGA Sector Rotation - The VGA Sector Rotation is a strategy managed by VGA that invests in an equity portfolio of S&P 500 sector ETFs based on their total return potential, as determined by VGA's proprietary ranking models. Top-ranked sectors determined will receive a higher portfolio weight, and bottom-ranked sectors determined will receive a lower weight or are held in cash. The strategy is offered in two versions: long-only and hedged. The long-only version will hold cash in sectors that are bottom-ranked; otherwise, it remains fully invested regardless of the market backdrop. The hedged version deploys a risk-managed approach whereby equity exposure is reduced when our macro models determine the investment backdrop has deteriorated. The minimum account size is $10,000. VGA Style Flex - The VGA Style Flex is a strategy managed by VGA that invests in a targeted portfolio of individual stocks and ETFs selected to emphasize market preference for either growth or value stocks. Growth or value attractiveness is determined through a proprietary blend analysis of relative strength and breadth factors. The strategy is designed to provide strong equity market participation during neutral to bullish investment backdrops, as determined by VGA's macro models, with an emphasis on the predominant equity style that appears to be in favor (growth or value). When neither style appears to be in favor, the strategy's focus shifts towards capital preservation by reducing overall equity exposure. Equity exposure can range from 100% net long during maximum bullish backdrops to 0% during maximum bearish backdrops. The minimum account size is $75,000. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. 25  When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. 26  The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for 27  receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. 28  Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund 29  will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected 30  project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. 31  Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. 32  Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. 33  Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a 34  warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike 35  price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move 36  against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser 37  Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of VAM. Integrated is an independent registered investment adviser that provides only investment advisory services. Integrated does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. an investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. 38  Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. VGA and its associated persons do not have any other financial industry activities or affiliations. Ownership Interest and Related Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since certain IARs sold an ownership or financial interest in VGA or a VGA-affiliated entity and may have a financial incentive to submit advisory clients to specific companies, strategies, programs, or services over others due to compensation received or other economic benefits in connection with such relationships, rather than client need. The Adviser addresses these conflicts of interest by requiring Associates to always act in each client’s best interest when making recommendations and to fully disclose such relationships prior to or at the time of any recommendation. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid or received before transaction execution. When acting in this capacity, the firm’s policy requires Associates to communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser, or under any Integrated Investment Management Agreement. Clients are under no obligation to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered, including VGA-related strategies or services. Clients may obtain similar advisory services from other advisers or unaffiliated providers. The ultimate decision to accept any recommendation and retain products or services remains at the client’s sole discretion. Additional details regarding how VGA and the Adviser identify, disclose, and mitigate conflicts of interest are set forth in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics (“Code”). A copy of the Code is available for review free of charge to any client or prospective client upon request. 39  Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. 40  To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: 41  • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • 42  Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research 43  services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. 44  Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client 45  Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. 46  Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or 47  Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction 48  or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw any money, securities, or other property from any client custodial account in the client's name or otherwise. However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 49  5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated 50  or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to 51  participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 52 

Item 1 – Cover Sheet Vineyard Global Advisors, LLC Form ADV Part 2A Appendix 1 – Wrap Fee Brochure (CRD #171991 / SEC #801-96203) 9800 Mt. Pyramid Ct. Suite 400 Englewood, CO 80112 Telephone: 303-814-6818 www.vineyardglobaladvisors.com March 31, 2026 Officer of Integrated Advisors Network at 855-729-4222 This Form ADV Part 2A, Appendix 1, Wrap Fee Program brochure (“brochure”) provides information about the qualifications and business practices of Vineyard Global Advisors, LLC, a DBA of Integrated Advisors Network, an investment adviser registered with the United States Securities and Exchange Commission ("SEC"). If you have questions about this Brochure's contents, please contact Tom R. Samuelson, Chief Investment Officer of Vineyard Global Advisors, LLC, at 720-470-3252 or tom@vineyardglobaladvisors.com or Danielle L. Tyler, Chief Compliance or compliance@integratedadvisorsnetwork.com. The information in this Brochure has not been approved or verified by the SEC or any state securities authority. Nothing in this document is to be construed as a recommendation or an endorsement by the SEC or any state securities authority or an offer of securities; refer to the actual investment offering and related legal documentation for complete disclosures. Please note that registration as an investment adviser does not imply a certain level of skill or training. An adviser's written and oral communications provide information to determine whether to retain the adviser's services. This Brochure is on file with the appropriate regulatory authorities as Federal and state regulations require. Additional information about Vineyard Global Advisors, LLC and Integrated Advisors Network, LLC is also available on the SEC's website at www.adviserinfo.sec.gov. (Click on the link, select "Investment Adviser- Firm," and type in our firm name or CRD #171991. Results will provide you with all firm disclosure brochures.) 1  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Adviser") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since the last annual updating amendment of March 31, 2025, changes have been made to the following Brochure sections: There have been no material changes since the last annual updating amendment. Full Brochure Availability We may amend this document at any time to reflect changes in our business practices, policies, or procedures, or to reflect updates mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients - either by electronic means or hard copy with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at www.adviserinfo.sec.gov by searching either our name or CRD #171991. The SEC's website also provides information about any advisory-affiliated person registered or required to be registered as an Investment Adviser Representative of the firm. You may also request a copy free of charge by contacting us directly at the number(s) located on this Brochure's cover page. 2  Item 3 – Table of Contents Item 1 – Cover Sheet ........................................................................................................................................... 1 Item 2 – Material Changes ................................................................................................................................... 2 Item 3 – Table of Contents ................................................................................................................................... 3 Item 4 – Services, Fees and Compensation ........................................................................................................... 4 Item 5 – Account Requirements and Types of Clients .......................................................................................... 8 Item 6 – Portfolio Manager Selection and Evaluation ........................................................................................... 8 Item 7 – Client Information Provided to Portfolio Managers .............................................................................. 16 Item 8 – Client Contact with Portfolio Managers ................................................................................................ 17 Item 9 – Additional Information......................................................................................................................... 17 3  Item 4 – Services, Fees and Compensation The Vineyard Global Advisors Managed Advisory Program (“VGA MAP” or the “Program”) is an investment advisory program sponsored and administered by Vineyard Global Advisors, a dba of Integrated Advisors Network LLC (“Integrated”) The Program provides clients with the ability to pay a single fee for the management, brokerage, custody and other services provided under the Program. Vineyard Global Advisors, a dba of Integrated Advisors Network LLC is a registered investment adviser. All accounts participating in the Program are held with a Qualified Custodian (such as Charles Schwab, Fidelity, etc.), who are unaffiliated broker-dealer. The Qualified Custodian maintains custody of the client’s funds and securities; collects interest and dividends; and performs the normal and customary execution and custodial services. The Qualified Custodian will send clients confirmation of each transaction in their VGA MAP account(s) and will send account statements reflecting activity in the client’s VGA MAP account at least quarterly. To join the Program, a client must (1) complete an investor profile that describes the client’s financial needs, investment objectives, time horizon, and risk tolerance, as well as any other factors relevant to the client’s specific financial situation and any other supporting documentation the Program requires; (2) execute the investment advisory WRAP fee agreement (the “Agreement”) with the Adviser; (3) complete a new account agreement with the approved Qualified Custodian that participates in the Program; and (4) open a securities brokerage account with the approved Qualified Custodian and deposit those assets designated for participation in the Program into the account. Account Services The Adviser’s investment advisor representatives (“IARs”) provide investment portfolio advice and supervisory services to clients based on an individual’s financial information, goals and objectives. This investment advice varies depending upon a client’s individual life situation, desires, objectives, and other preferences. IARs use the information initially provided in the investment profile to assist the client in developing an appropriate investment strategy for the assets in his or her account(s). Thereafter, all clients are encouraged to discuss their needs, goals, and objectives with their IAR and to notify the Adviser of any changes. The Adviser requires its IARs to contact clients at least annually to review previous services and/or recommendations and to determine whether changes should be made to the client’s investment strategy. Clients will authorize the Adviser to have trading authorization on their account and the Adviser’s IARs will provide asset management services. Clients will authorize either discretionary or non-discretionary management in the Agreement for the Program. If a Client authorizes the Adviser to provide asset management services on a discretionary basis, the IAR will make all decisions to buy, sell or hold securities, cash, or other investments in the client’s managed account in the IAR’s sole discretion without consulting with the client before making any transactions. Clients must provide written authorization to exercise this discretionary authority. Clients cannot place any restrictions and limitations on the Adviser’s discretionary authority. The Adviser is the manager and program sponsor to the Vineyard Global Advisors Managed Advisory Program (VGA MAP), whereby client accounts are managed for a calculated fee, subject to a fee minimum, that includes both management services and securities transaction/commission costs. VGA MAP is offered to prospective and existing advisory clients is designed to make asset management services available to clients for a convenient single "WRAP fee". Depending upon the number of transactions executed in the client’s account, the overall cost the client will incur if they participate in the WRAP fee program may be higher or lower than they might incur by separately purchasing the types of securities available in VGA MAP. Prior to becoming a client under VGA MAP, the client will be required to enter into a separate written agreement with the Adviser that sets forth the terms and conditions of the engagement and describes the scope of the services to be provided, and the fees to be paid. 4  VGA also has entered into written agreements with certain unaffiliated third party investment advisers to serve as a sub-adviser and provide investment management services to the third party advisers’ clients. Under these sub- advisory arrangements, each third party investment adviser is responsible for working with its clients to select the appropriate strategy for investment. VGA manages the clients’ designated assets based on the respective selected investment strategy. Model Portfolio Investment Selection and Portfolio Management The client’s investment adviser representative (“IAR”) will assist clients in clarifying their investment needs, including but not limited to investment objectives, tolerance for risk, and investment time horizon, and provide professional advice. In an effort to assist the client in achieving his or her investment goals, the IAR will work with the client in selecting the appropriate asset manager(s) and/or strategy(ies) based on such factors as the manager’s selected risk adjusted returns and the client’s suitability needs. The client’s Agreement will document the manager(s) and strategies selected by the client. The asset manager(s) will provide investment management of each client’s funds on a discretionary basis through the client’s VGA MAP account. This written discretionary authority will be granted through limited Trading Authorization as detailed in the Agreement. Asset managers available through the VGA MAP will offer various model portfolios under this program. The model portfolios will include investments in, but not limited to, stocks, bonds, ETFs and mutual funds. The client has ability to withdraw securities or cash; vote securities; receive a written confirmation or other notification of each securities transaction and all other documents required by law to be provided to security holder; and proceed directly as a security holder against the issuer of any security in the client's account. The client can also impose reasonable restrictions on the management of the client's account, including the designation of particular securities or types of securities that should not be purchased for the account, or that should be sold if held in the account. Performance Evaluation and Monitoring Services The asset manager(s) for the client’s account will monitor, rebalance, and manage all of the changes to the client’s VGA MAP account. The Adviser will furnish quarterly performance measurement reports to its clients. These reports are intended to inform clients as to how their investments have performed during the selected period. Clients will also receive account statements from the Qualified Custodian at least quarterly, detailing all of the activity in the client’s account, including the amount of advisory fees paid directly to the Adviser. Information contained in the performance reports is believed to be accurate, however, the accuracy and completeness of the information is not guaranteed, and is not intended to replace the account statements clients receive from the Qualified Custodian. The statements clients receive from the Qualified Custodian should be considered the official record for all pertinent account information. Clients should compare the information contained in the Qualified Custodian’s account statement with the Adviser’s performance reports. Clients should promptly convey any discrepancies to their IAR or the Adviser’s home office. Clients should also notify the Adviser if they do not receive the account statements from The Qualified Custodian on at least a quarterly basis. Calculations and data provided on the performance reports should not be relied upon for tax purposes, but rather clients should use the original transaction confirmations and 1099s instead. Changes in Your Financial Circumstances The Adviser’s IARs make investment decisions for a client’s portfolio on a discretionary basis according to the client’s stated objectives, financial circumstances, and risk tolerance. The Adviser is not required to verify any information it receives from clients or from a client’s other professionals (e.g. attorney, accountant, etc.) and the Adviser is expressly authorized to rely on the information clients provide. Clients must promptly notify the Adviser of any change in financial circumstances or investment objectives that might affect the manner in which a client’s account(s) should be managed. 5  Program Fees The Adviser charges a single asset-based fee for advisory services, which includes the cost of portfolio management services, custodial services and the execution of securities transactions. The fee will be assessed and billed quarterly in advance. The fee for any given calendar quarter is debited by the custodian from the client’s account at the beginning of the calendar quarter, based on the total portfolio value as of the last business day of the preceding calendar quarter. Clients will receive a debit notice showing the fee for that quarter and how it was calculated. The first fee will be billed upon execution of the Agreement and will be based upon the opening value of the account. If the Agreement is executed at any time other than the first day of a calendar quarter, the payment will be prorated. The Adviser provides investment management services for an annual fee based on the amount of assets under management (portfolio value). The fee varies between 0.35% and 1.00%, based on the following tiered fee schedules: VGA ETF Advantage Series, VGA Allocation Plus Series, VGA Global Fixed Income Account Size Program Fee Up to $500,000 0.50% $500,000 - $1,000,000 0.45% $1,000,000 - $5,000,000 0.40% Over $5,000,000 0.35% VGA Advantage Plus, VGA R3000 Enhanced Dividend, VGA Enhanced S&P 500, VGA Dynamic Yield, VGA Covered Call, VGA Private Client Service, VGA Risk Managed Income, VGA Quantitative Value, VGA Quantitative Growth, VGA Sector Rotation, VGA Equity Style Flex, VGA Optimized Equity Alpha Account Size Up to $500,000 $500,000 - $1,000,000 $1,000,000 - $5,000,000 Over $5,000,000 Program Fee 0.75% 0.70% 0.65% 0.60% SpiderRock Proprietary Model Fees Proprietary Model SpiderRock Qualified Solutions – Conservative (SRQSC) SpiderRock Qualified Solutions – Moderate (SRQSM) SpiderRock Qualified Solutions – Growth (SRQSG) SpiderRock Hedged Equity Concentrated Stock (SRHEC) SpiderRock Hedged Equity Portfolio SpiderRock Cash Security Put (SRCSP) SpiderRock Structured Downside Protection (SRSDP) SRA Annual Fee 0.40% AUM 0.40% AUM 0.40% AUM 0.50% AUM 0.50% AUM 0.50% AUM 0.50% AUM 6  SpiderRock S&P CBOE BXM Replication SpiderRock S&P CBOE PUT Replication SpiderRock Negative Duration Equity (SRNDE) SpiderRock Structured Note Replication (SRSNR) SpiderRock Managed Index Income (SRMII) SpiderRock Opportunistic Yield Enhancement (SROYE) SpiderRock Exchange Fund Replication (SREFR) 0.50% AUM 0.50% AUM 0.60% AUM 0.60% AUM 0.60% AUM 0.70% AUM 0.85% AUM VGA Custom Covered Call The program fee is 1.00% for all account sizes. The Adviser may negotiate to charge a lesser fee based upon certain criteria such as size, type, and complexity of account; related accounts; anticipated changes in accounts; among other factors. Fee Comparison A portion of the fees paid to the Adviser are used to cover the securities brokerage commissions and transactional costs attributed to the management of its clients’ portfolios, the financial advice offered by the Adviser through the client’s selected IAR, as well as the fees charged by the asset managers engaged to provide services under the Program. The asset managers servicing accounts through the Program receive a fee based upon the assets under their management. Services provided through the Program may cost clients more or less than purchasing these services separately. The number of transactions made in a client’s account(s), as well as the commissions charged for each transaction, determines the relative cost of the Program versus paying for execution on a per transaction basis and paying a separate fee for advisory services. Fees paid for the Program may also be higher or lower than fees charged by other sponsors of comparable investment advisory programs. As the Adviser absorbs certain transaction costs in WRAP fee accounts, the Adviser may have a financial incentive not to place transaction orders in those accounts since doing so increases its transaction costs. Thus, an incentive exists to place trades less frequently in a WRAP fee arrangement. Additions, Withdrawals and Terminations Clients may make additions to and withdrawals from their account at any time in cash or securities. The Adviser reserves the right to liquidate any transferred securities or decline to accept particular securities into a client’s account. Clients must notify the Adviser upon withdrawing assets from their account. The Adviser advises clients that (1) when the Adviser liquidates transferred securities, they may be subject to additional fees such as transaction fees, fees assessed at the mutual fund level (i.e., contingent deferred sales charge) and/or tax ramifications and (2) withdrawals are subject to the usual and customary securities settlement procedures. If the client terminates his or her account during any billing period, the Adviser will refund the client’s account any pre-paid advisory fees on a pro-rata basis from the date of termination to the end of the billing period. For amounts withdrawn from an existing account during the quarter, any pre-paid advisory fee for those assets will be refunded on a pro-rata basis from the date of the withdrawal to the end of the billing period, and credited to the account during the next billing cycle. Additionally, if the client transfers his or her account to another firm, the client may pay an outgoing account transfer fee. Integrated Fee Disclosure The clients of Vineyard Global Advisors will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may 7  vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. VGA’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that VGA2 fees are the lowest available for similar services. Other Charges There may be other costs assessed by third parties and/or the Adviser, which are not included in the Program Fee. For example, there may be charges imposed directly by a mutual fund or exchange-traded fund in the account (e.g. fund management fees and other fund expenses as disclosed in the prospectus), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, annual check writing and debit card fees, check stop payment fees, returned check fees, ACH return fees, security transfer and redemption fees, reorganization processing fees, trade confirmation fees, outgoing account transfer fees, margin extension fees, margin debit interest, IRA annual maintenance fees, IRA termination fees, amounts charged to produce year-end statements and account reports, and other fees and taxes on brokerage accounts and securities transactions and fees for trades executed away from custodian. Clients may obtain a schedule of these additional fees by contacting their IAR or the Adviser. Compensation The Adviser’s IARs receive a portion of the advisory fee that clients pay to the Adviser as a percentage of the client’s overall advisory fee. This creates an incentive for IARs to recommend that clients participate in a WRAP fee program rather than a non-WRAP fee program (where clients pay for trade execution costs) or brokerage account where commissions are charged. In some cases, the Adviser may stand to earn more compensation from advisory fees paid to the Adviser through a WRAP fee program arrangement if a client’s account is not actively traded. In addition, the Adviser may have arrangements in place with other management personnel and/or affiliates through which profits are split per agreed-upon terms. Item 5 – Account Requirements and Types of Clients The Adviser generally provides investment advice to individuals, high net worth individuals, pension and profit sharing plans, trusts, estates, or charitable organizations, and corporations or business entities. Client relationships vary in scope and length of service. Minimum Account Size Certain strategies or sleeves available through the Program may list different minimums. Unless otherwise stated in the client’s Agreement and applicable program materials, the Program’s minimum account size is $50,000. Strategy-level minimums reflect the minimums applicable to that specific strategy when available through the Program and may be satisfied through an eligible account structure, aggregation of related accounts, or an approved exception, as applicable. Item 6 – Portfolio Manager Selection and Evaluation Selecting and Reviewing Portfolio Managers The Adviser acts as the sponsor and portfolio manager under the Program. Clients’ investment portfolios are managed either directly by the Adviser or through the use of certain asset managers (see above). The Adviser uses a detailed due diligence process to evaluate and approve asset managers for the VGA MAP. Factors influencing selection of an asset manager include, but are not limited to, accessibility; ability to customize, knowledge of products currently offered, tenure, relative cost, education, and knowledge of general economic and market factors 8  and other criteria. The Adviser also reviews performance numbers provided the asset managers and other third- party reporting sources in its evaluation process. The Adviser will offer the investment management services of numerous professional asset managers. The Adviser continues to monitor the performance of all asset managers participating in the Program to make certain they are continually providing the performance and value for which they were selected. The Adviser seeks to ensure the asset managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. The Adviser may eliminate an asset manager who is under-performing from the platform at its. In the event that an asset manager needs to be replaced, the Adviser has the sole discretion to hire a new asset manager and adjust the weighting of the allocation accordingly. In evaluating portfolio managers, the Adviser reviews performance information provided by portfolio managers and/or derived from custodian and third-party reporting data. Performance is generally evaluated on a total-return basis over multiple time periods and is considered in the context of strategy objectives, risk characteristics, and market conditions. Unless specifically stated otherwise, the Adviser does not independently audit or verify portfolio manager performance calculations for accuracy or for compliance with any particular performance presentation standards, and performance information may not be calculated on a uniform and consistent basis among portfolio managers. Clients should refer to their qualified custodian statements and other official account documentation as the primary record of account activity. Related Persons as Portfolio Managers The Adviser and its related persons act as portfolio manager(s) for the WRAP fee program(s) previously described in this WRAP Fee Program Brochure. This creates a conflict of interest in that portfolio managers could place their own or the Adviser's interests before a client’s interest. The Adviser has adopted Compliance Procedures and a Code of Ethics that requires the Adviser’s portfolio managers and other employees of the Adviser to adhere to their fiduciary duty and avoid activities, interests and relationships that run contrary (or appear to run contrary) to the best interests of clients. The Adviser uses the same detailed due diligence process described above to evaluate and approve related portfolio asset managers for the VGA MAP as it does for outside managers. Advisory Business Vineyard Global Advisors LLC is a DBA of Integrated Advisors Network, an investment advisor registered with the Securities and Exchange Commission ("SEC") pursuant to the Investment Advisers Act of 1940 (the "Advisers Act") (collectively and hereafter referred to as "VGA" or "the Adviser”). Integrated, organized as a limited liability company in 2014, has been SEC-registered since May 11, 2015. The Adviser is a fee-only investment management firm. The Adviser provides personalized investment advice primarily to other investment advisers or Investment Adviser Representatives. However, occasionally the Adviser will work with to individuals, high net worth individuals, pension and profit sharing plans, trusts, estates or charitable organizations, and corporations or other business entities directly. The Adviser does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The Adviser is not affiliated with entities that sell financial products or securities. The Adviser does not act as a custodian of client assets and the client always maintains asset control. The Adviser has discretion of client accounts and places trades for clients under a limited power of attorney. The Adviser acts as a sponsor and does provide investment advice to a WRAP program through Integrated Advisors Network LLC. The goals and objectives for each client are documented in our client relationship management system, Investment Policy Statements, and/or Investor Questionnaires. Clients may impose restrictions on investing in certain securities or types of securities. 9  Performance-Based Fees and Side-by-Side Management The Adviser does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). Methods of Analysis, Investment Strategies and Risk of Loss Security analysis methods may include charting, fundamental analysis, technical analysis and cyclical analysis. Strategies may include long-term purchases, short-term purchases, trading, short sales, margin transactions, and option writing (including covered options, uncovered options or spreading strategies). Each IAR may use a different investment methodology when managing client assets based upon the objectives stated by the client. The Adviser does not represent, warrant, or imply that the services or methods of analysis used by the Adviser can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections, crashes, or extraordinary events. The Adviser cannot assure clients’ goals or objectives will be achieved or its advisory services will provide a better return than other investment strategies. Investing in securities involves risk of loss that clients should be prepared to bear. Past performances of any recommended managers or funds or securities, or the success of a manager is no guarantee of future success. There can be no assurance that clients will not incur losses. The following risk factors are not intended to be a full or complete listing of all the risks involved in investing, and clients should engage in their own evaluation of such risks. Interest-Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, the face value on existing bonds becomes less attractive, causing their market values to decline. Similarly, equities may also suffer from a rising interest rates. Therefore, in real terms, client portfolios may not keep up with the rate of inflation. Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions may trigger market events that may cause prices to fall. Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. Investments made in foreign countries may depreciate if the corresponding value of the country’s currency goes down. Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (e.g., interest rate). This primarily relates to fixed income securities. Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of potential profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many individuals are interested in buying or selling a standard asset or product. For example, Treasury Bills are highly liquid, while real estate properties are not. 10  Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Additional risks may be disclosed for different advisory groups at Integrated. For a detailed list of risks for an advisory group, refer to that group’s ADV Part 2A. VGA MAP currently includes the following asset management strategies: VGA ETF Advantage Series The VGA ETF Advantage series are a group of managed asset allocation strategies offered by Vineyard Global Advisors (VGA) that utilize exchange traded funds (ETF’s) in five custom market models that range from capital preservation (10% equity - 90% fixed income) to aggressive growth (90% equity - 10% fixed income). The models are offered in both tax-sensitive and qualified versions. The strategies provide exposure to nine different asset classes that include US equities, foreign developed equities, emerging market equities, fixed income, real estate, master limited partnerships, commodities, alternatives and cash. Broad diversification across these asset classes provides a primary layer of risk management while additional downside protection is provided by tactical asset class adjustments and the use of opportunistic hedge positions based on input from our macro models. Exchange Traded Funds offer low operating costs, tax efficiency and low minimum investment entry levels, making the ETF Advantage strategy available to lower account sizes (minimum $10,000). VGA Allocation Plus Series The VGA Allocation Plus series are a group of managed asset allocation strategies offered by Vineyard Global Advisors (VGA) that utilize mutual funds and exchange traded funds (ETF’s) in five custom market models that range from capital preservation (10% equity - 90% fixed income) to aggressive growth (90% equity - 10% fixed income). The models are offered in both tax-sensitive and qualified versions. Actively-managed mutual funds are selected through proprietary research designed to identify those managers that have been able to consistently offer returns above their respective asset categories (manager “alpha”). In asset categories where little additional alpha can be obtained through active management, that category is sourced with a passive ETF. The strategies provide exposure to nine different asset classes that include US equities, foreign developed equities, emerging market equites, fixed income, real estate, master limited partnerships, commodities, alternatives and cash. Broad diversification across these asset classes provides a primary layer of risk management while additional downside protection is provided by tactical asset class adjustments and opportunistic hedge positions based on input from our macro models. Several of the mutual funds require higher minimum initial investment levels, making this strategy available for account sizes of $100,000+. VGA Advantage Plus Series The VGA Advantage Plus Series are a group of managed asset allocation strategies offered by Vineyard Global Advisors (VGA) that utilize mutual funds, exchange traded funds (ETF’s) and internal proprietary investment strategies in five custom market models that range from capital preservation (10% equity - 90% fixed income) to aggressive growth (90% equity - 10% fixed income). The Allocation Advantage Plus strategy is offered in a unified managed account (UMA) format, which is a sophisticated design that combines multiple investment vehicles into a single portfolio account, maximizing efforts to enhance diversification. The models are offered in both tax- sensitive and qualified versions. The strategy utilizes both VGA-actively managed strategies and mutual funds that have been selected through proprietary research designed to identify managers that have been able to consistently offer returns above their respective asset categories (manager “alpha”). The internal strategies and mutual funds are included in an effort to maximize risk-adjusted returns. In asset categories where active management has provided 11  minimal alpha, that category is sourced with a passive ETF. The strategies provide exposure to nine different asset classes that include US equities, foreign developed equities, emerging market equities, fixed income, real estate, master limited partnerships, commodities, alternatives and cash. Broad diversification across these asset classes provides a primary layer of risk management while additional downside protection is provided by tactical asset class adjustments and opportunistic hedge positions based on input from our macro models. Several mutual funds and the internal strategies require higher minimum investment levels, making this strategy available for account sizes of $500,000+. VGA R3000 Enhanced Dividend The VGA R3000 Enhanced Dividend strategy is a proprietary strategy managed by VGA that invests primarily in dividend-paying US stocks that are selected through a proprietary screening process developed to identify companies that may offer above-average total return potential, with a primary focus on income. The strategy may also invest in income producing American Depository Receipts (“ADRs”), Exchange Traded Funds (“ETFs”), and Closed-End Funds (“CEFs”). The strategy deploys a risk-managed approach whereby equity exposure is reduced when our macro models determine the investment backdrop has deteriorated. Equity exposure can range from between 25% net long (during maximum negative market backdrops) to 125% net long (during maximum positive market backdrops). Minimum account size: $25,000. VGA Enhanced S&P 500 The VGA Enhanced S&P 500 strategy is a proprietary strategy managed by VGA that invests in S&P 500 stocks that are selected through a proprietary screening process developed to identify companies that may offer above- average total return potential. The strategy deploys a risk-managed approach whereby equity exposure is reduced when our macro models suggest the investment backdrop has deteriorated. Equity exposure can range from -5% net long (during maximum negative market backdrops) to 120% net long (during maximum positive market backdrops). VGA Enhanced S&P 500 seeks to outperform the S&P 500 index with a bias toward downside risk management. The strategy is designed to provide equity market participation during bullish phases as determined by our macro models while attempting to provide downside protection when our macro models suggest the equity market backdrop has deteriorated. Minimum account size: $25,000. VGA Global Fixed Income The VGA Global Fixed Income strategy is a proprietary fixed income allocation strategy managed by VGA that invests in fixed income Exchange Traded Funds (ETF’s), Closed-end Funds (“CEF’s”) and mutual funds. The strategy invests across 22 fixed income categories selected for their diversification attributes. The strategy is offered in both tax-sensitive and qualified versions. Risk management may be further enhanced through the use of ETF hedge positions, which can be included to manage interest rate and credit risk, depending upon input from our macro models. The VGA Global Fixed Income strategies are intended for investors with low risk tolerance and to provide portfolio diversification benefits when added to higher volatility equity allocations. Minimum account size: $10,000. VGA Dynamic Yield The VGA Dynamic Yield is an income-focused strategy that invests in U.S. dividend paying stocks, American Depository Receipts (“ADR’s), Closed-end mutual funds (“CEF’s”) and Open-end mutual funds. Its primary objective is to offer risk-managed income sourced through dividends, interest income and royalty payments. It seeks to achieve its objective by investing across a portfolio of approximately 65 positions that offers exposure to all the major, publicly-traded income producing asset categories. Risk management is achieved through: 1) broad diversification across asset classes, 2) dynamic adjustment of the equity and fixed income portions of the portfolio (based on input from our macro models) and, 3) the use of opportunistic ETF hedge positions to further address equity, credit and interest rate risk. Minimum account size: $25,000. 12  VGA Covered Call VGA Covered Call is a proprietary separately managed account strategy that seeks attractive risk- adjusted returns through the purchase of a diversified equity portfolio and concurrent sale of call options which may provide partial downside protection plus the potential for auxiliary income generation. The portfolio consists of 16 - 35 individual covered call positions that are diversified by sector, strike price and expiration date. Individual stocks are systematically selected through proprietary screens and then scored using a multi- factor model that evaluates their attractiveness at time of purchase. Minimum account size: $150,000. VGA Custom Covered Call The VGA Custom Covered Call strategy is offered on an account by account basis as a way for clients to generate auxiliary income on concentrated equity positions through the sale of call options. First, the client determines a level at which he/she is indifferent to selling the underlying stock position. Then, VGA deploys an opportunistic covered call writing program around the agreed upon exit price with an eye towards trading the calls for a profit should the overall stock market or that particular stock decline in value. Minimum account size: $1,000,000. VGA Optimized Equity Alpha VGA Optimized Equity Alpha is a strategy managed by VGA that invests in US-listed stocks and exchange traded funds (ETF’s), seeking to achieve its objective of long-term capital appreciation by combining a sector rotation strategy and a style preference strategy (growth vs. value). These two different approaches are combined into one strategy due to their diversification benefits. The strategy is designed to provide strong equity market participation during neutral to bullish investment backdrops (as determined by VGA’s proprietary macro models) with a focus on capital preservation during bearish investment backdrops. Equity exposure can range from 100% net long during maximum bullish backdrops to 0% during maximum bearish backdrops. Minimum account size: $150,000. VGA Private Client Services (“PCS”) The VGA Private Client Services (“PCS”) provides customized portfolio construction solutions to high net- worth clients (generally liquid net worth in excess of $1,000,000). Customized portfolios solutions are designed and implemented after consultation with an advisor that seeks to determine the appropriate allocation based on the client’s individualized investment objectives and/or financial plan. An open architecture environment is utilized that may invest across a broad array of stocks, bonds, exchange- traded funds, closed and open end mutual funds, proprietary internal strategies and alternative and structured investment products. VGA PCS is offered in a unified managed account (UMA) format, which is a sophisticated design that combines multiple investment vehicles into a single portfolio account, maximizing efforts to enhance diversification. Minimum account size: $1,000,000. VGA Risk Managed Income The VGA Dynamic Yield is an income-focused strategy that invests in U.S. dividend paying stocks, American Depository Receipts (“ADR’s), Closed-end mutual funds (“CEF’s”) and Open-end mutual funds. Its primary objective is to offer a low-volatility, risk-managed income solution sourced through dividends, interest income and royalty payments. Risk Management is achieved through: 1) constraining equity exposure to a maximum of 30% of the overall strategy, 2) dynamic adjustment of the equity and fixed income portions of the portfolio (based on input from our macro models) and, 3) the use of opportunistic ETF hedge positions to further address equity, credit and interest rate risk. Minimum account size: $25,000. VGA Quantitative Value The VGA Quantitative Value is a strategy managed by VGA that invests in a targeted portfolio of approximately 50 top-ranked stocks in the Russell 3000 Value index selected through a proprietary screening process designed to identify companies with above-average total return potential. The screening process seeks to identify companies with a unique blend of value, quality, profitability, growth, and price momentum attributes that have historically been associated with superior stock performance. The strategy is offered in two versions: long-only and hedged. 13  The Long-only version remains at least 80% invested regardless of the market backdrop. The hedged version will scale overall portfolio equity exposure from 0% net long to 100% net long during maximum bearish to maximum bullish market backdrops, respectively. The strategy is rebalanced quarterly, although individual positions may be adjusted opportunistically. The minimum account size is $50,000. VGA Quantitative Growth VGA Quantitative Growth is a strategy managed by VGA that invests in a targeted portfolio of approximately 50 top-ranked stocks in the Russell 3000 Growth index selected through a proprietary screening process designed to identify companies with above-average total return potential, utilizing a "growth at a reasonable price" or GARP methodology. The screening process seeks to identify companies with a unique blend of earnings growth, earnings momentum, earnings consistency, valuation and price momentum attributes that have historically been associated with superior stock performance. The strategy is offered in two versions: long-only and hedged. The long-only version remains at least 80% invested regardless of the market backdrop. The hedged version will scale overall portfolio equity exposure from 0% net long to 100% net long during maximum bearish to maximum bullish market backdrops, respectively. The strategy is rebalanced quarterly, although individual positions may be adjusted opportunistically. Minimum account size: $50,000. VGA Sector Rotation VGA Sector Rotation is a strategy managed by VGA that invests in an equity portfolio of S&P 500 sector exchange traded funds (ETF’s) based upon their total return potential, as determined by VGA’s proprietary ranking models. Top-ranked sectors determined will receive a higher portfolio weight and bottom-ranked sectors determined will receive a lower weight (or are held in cash). The strategy is offered in two versions: long-only and hedged. The long-only version will hold cash in sectors that are bottom-ranked, otherwise it remains fully invested regardless of market backdrop. The hedged version deploys a risk-managed approach whereby equity exposure is reduced when our macro models determine the investment backdrop has deteriorated. Minimum account size: $10,000. VGA Style Flex VGA Style Flex is a strategy managed by VGA that invests in a targeted portfolio of individual stocks and ETF’s selected to emphasize market preference for either growth or value stocks. Growth or value attractiveness is determined through a proprietary blend analysis of relative strength and breadth factors. The strategy is designed to provide strong equity market participation during neutral to bullish investment backdrops (as determined by VGA’s macro models) with an emphasis on the predominant equity style that appears to be in favor (growth or value). When neither style appears to be in favor, the strategy’s focus shifts towards capital preservation by reducing overall equity exposure. Equity exposure can range from 100% net long during maximum bullish backdrops to 0% during maximum bearish backdrops. Minimum account size: $75,000. SpiderRock Hedged Equity Concentrated Stock (SRHEC) A risk management option overlay model which seeks to hedge downside risks for concentrated stock positions. The strategy uses options and combinations of options to construct a hedge structure that protects the underlying securities from large downside moves, whiles at the same time preserving a portion of the upside. The strategy seeks a consistent reduction in stock volatility, while also allowing Program Clients to maintain their current stock positions and its dividends. The option positions are dynamically rebalanced during times of market volatility, and systematically implemented to take advantage of option pricing inefficiencies. SpiderRock Advisors allows for up to three tickers per Allocated Sleeve. SpiderRock Hedged Equity Portfolio (SRHEP) A risk management option overlay model which uses option combinations of puts and calls to construct a dynamic collar structure that protects the underlying portfolio from large downside moves, while at the same time preserving 14  a portion of the upside. The strategy seeks a consistent reduction in portfolio volatility, while also allowing Program Clients to maintain their underlying portfolio positions and dividends. The option positions are dynamically rebalanced during times of market volatility, and systematically implemented to take advantage of option pricing inefficiencies. SpiderRock Cash Secured Put (SRCSP) The objective of SRSCSP is to write puts systematically against cash in Program Client’s Allocated Sleeves. This allows a Program Client to potentially enhance portfolio yield, and acquire long positions in the underlying securities, should the price of the underlying security decline by a predetermined amount. The SRCSP program can be implemented on 50/75/100 allocation of the Allocated Sleeve in which the SRCSP program is applied, and is available in taxable and non-taxable Allocated Sleeves. SpiderRock Structured Downside Protection (SRSDP) The objective of SRSDP is to create a dynamic structure of puts and/or calls to buffer Program Client’s Allocated Sleeves from downside moves in equities. This allows a Program Client to potentially avoid some of a downside move, should the price of their underlying equities decline during a discrete period of time. The SRSDP program can be implemented on taxable accounts, covering a 25/50/75/100 allocation of the Allocated Sleeve. SpiderRock S&P CBOE BXM Replication (SRBXM) The objective of the SRBXM is to replicate the options component of the Standard and Poor’s CBOE BXM (BuyWrite) index. Using the CBOE BXM prospectus as a template, this strategy sells At The Money calls on a monthly basis against the beta of the underlying positions in the Allocated Sleeve. The SRBXM program can be implemented on 25/50/75/100 allocation of the Allocated Sleeve in which the SRBXM program is applied, and is available in taxable Allocated Sleeves only. SpiderRock S&P CBOE PUT Replication (SRPUT) The objective of SRPUT is to replicate the options component of the Standard and Poor’s CBOE PUT (PutWrite) index. Using the CBOE PUT prospectus as a template, this strategy sells the first Out of The Monet puts on a monthly basis against a portfolio of cash or T-bills in an Allocated Sleeve. The SRPUT program can be implemented on $250,000 increments and is available in taxable and non-taxable Allocated Sleeves. SpiderRock Negative Duration Equity (SRNDE) This strategy seeks to create long equity exposure through listed index options. The current low-interest rate environment has created a scenario wherein the interest rate variable is also positively correlated to moves in interest rates, allowing for an increase in value if rates rise, and a decrease in value if rates decline. For Program Clients who are already exposed to interest rate risk through fixed-income holdings in their Allocated Sleeves, the SRNDE program seeks to hedge that exposure through the “negative duration” associated with the interest rate variable within the options. SpiderRock Managed Index Income (SRMII) An option overlay model which allows Program Clients to profit from the excess premium that is generally attached to major market, index options. The SRMII program sells index calls options to target a net long market exposure of 40 – 60% for a combined stock-options Allocated Sleeve. The SRMII program has been designed as a cost effective, hedging vehicle, and can be implemented on a 25.50/75/100 % allocation of the Allocated Sleeve in which the SRMII program is applied. The SRMII program is only available in taxable Allocated Sleeves. SpiderRock Structured Note Replication (SRSNR) The objective of SRSNR is to structure a payoff profile at a future date in alignment to client views using listed derivatives and eligible collateral instruments. This allows an investor to create a profile that equity and/or fixed 15  income would not be able to achieve. Strategy structures tend to provide less downside and tailored upside given market conditions versus the long only equivalent. The program can be cash or security collateralized, and is available in taxable and non-taxable accounts (certain structures). SpiderRock Opportunistic Yield Enhancement (SROYE) The objective of SROYE is to write calls opportunistically against Program Clients’ Allocated Sleeves, single securities, and broad based indices, thus allowing a Program Client to potentially enhance portfolio yield while possibly lowering portfolio volatility by monetizing the volatility of the Program Client’s underlying positions in the Allocated Sleeve. The SROYE program can be implemented on a 50/75/100% allocation of the Allocated Sleeve, and is available in taxable and non-taxable Allocated Sleeves. SpiderRock Exchange Fund Replication (SREFR) SREFR is a risk management option overlay model that seeks to reduce market exposure to concentrated single name equity positions while replacing it with exposure to a broad based index in order to reduce idiosyncratic risk in an Allocated Sleeve. THE SREFR program uses options and combinations of options to construct a hedge structure that protects the underlying securities from large downside moves, while at the same time preserving a portion of the upside. Additionally, the SREFR program uses options to create synthetic long exposure to a broad based index. The option positions are dynamically rebalanced during times of market volatility, and systematically implemented to take advantage of option pricing inefficiencies. SpiderRock Qualified Solutions – Conservative (SRQSC) A risk management option overlay model which seeks to reduce market exposure to a diversified equity and fixed income allocation. Through the use of covered call selling and protective put purchases, the strategy seeks to mitigate risk from equity market movements, while generating premium from selling covered calls. SpiderRock Qualified Solutions – Moderate (SRQSM) A risk management option overlay model which seeks to partially reduce market exposure of a diversified equity and fixed income allocation. Through the use of covered calls, the strategy seeks to achieve long-term growth while generating income in addition to equity dividends and portfolio yields, which may help to mitigate risk from equity market movements. SpiderRock Qualified Solutions – Growth (SRQSG) An option overlay model which seeks to partially reduce market exposure of a diversified equity and fixed income allocation. Through the use of covered calls, the strategy seeks to achieve long-term growth while generating income in addition to equity dividends and portfolio yields, which may help to mitigate risk from equity market movements. Voting Client Securities The Adviser will not vote nor advise clients how to vote proxies for securities held in client accounts. The client keeps the authority and responsibility for the voting of these proxies. The Adviser does not give any advice or take any action with respect to the voting of these proxies. For accounts subject to the provisions of the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary specifically keeps the authority and responsibility for the voting of any proxies for securities held in plan accounts. The custodian will promptly forward any proxy voting information to clients or their representatives. Item 7 – Client Information Provided to Portfolio Managers The Adviser gathers information (such as financial information, investment objectives, and risk tolerance) regarding clients to aid in providing appropriate and suitable investment advice regarding participation in the VGA MAP and 16  the Privacy Policy from selection of the appropriate portfolio. The Adviser shares this information only when necessary for processing or administering your account. Please consult the Adviser’s privacy policy for further details about information sharing. Clients may obtain a copy of the Adviser’s website at www.vineyardglobaladvisors.com or upon request to your IAR. Item 8 – Client Contact with Portfolio Managers The Adviser serves as the program sponsor and the portfolio manager. There are no restrictions placed on a client’s ability to contact and consult with the Adviser. Clients should contact the Adviser directly with any questions regarding their account. Item 9 – Additional Information Disciplinary Information On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Other Financial Industry Activities and Affiliations VGA is a dba of Integrated, an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. an investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Code of Ethics The Adviser has adopted a Code of Ethics for the purpose of instructing its personnel in their ethical obligations and to provide rules for their personal securities transactions. The Adviser and its personnel owe a duty of loyalty, fairness and good faith towards their clients, and the obligation to adhere not only to the specific provisions of the Code but to the general principles that guide the Code. The Code of Ethics covers a range of topics that may include: general ethical principles, reporting personal securities trading, exceptions to reporting securities trading, reportable securities, initial public offerings and private placements, reporting ethical violations, distribution of the Code of 17  Ethics, review and enforcement processes, amendments to Form ADV and supervisory procedures. The Adviser will provide a copy of the Code of Ethics to any client or prospective client upon request. Participation or Interest in Client Transactions The Adviser or individuals associated with the Adviser may buy or sell securities identical to those recommended to clients for their personal accounts. In addition, any related person(s) may have an interest or position in a certain security, which may also be recommended to a client. Under the Adviser’s Code of Ethics, the Adviser and its managers, members, officers and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers, and employees may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Personal Trading The Chief Compliance Officer reviews all employee trades each quarter (except for his/her own trading activity that is reviewed by another principal or officer of the Adviser). The personal trading reviews ensure that the personal trading of employees does not affect the markets, and that clients of the Adviser receive preferential treatment. Review of Accounts IARs will conduct periodic reviews of client accounts. IARs may meet with clients as frequently as is agreed upon or as is requested by the client or IAR. In most cases, a meeting of some kind will occur at least annually. IARs must extend to clients the opportunity to discuss their account(s) on at least an annual basis. At this meeting, or at other times as appropriate, the IAR should note any updates or changes to a client’s financial situation, goals and objectives. An Adviser principal periodically reviews Program accounts to identify issues or activity which may require further research and/or action. Clients will receive account statements directly from the account custodian, as well as periodic performance reports. The Adviser urges clients to compare the information provided on performance closely to the information presented on the account statements provided by the account custodian. Clients should defer to the custodian’s account statements where discrepancies are noted. Clients can direct any questions about account statements to the custodian or the Adviser. Client Referrals and Other Compensation Incoming Client Referrals The Adviser receives client referrals, which may come from current clients, estate planning attorneys, accountants, employees, personal friends of employees and other similar sources. The firm does not compensate referring parties for these referrals. Promoter Referrals The Adviser has not entered into any promoter (formerly known as solicitor) relationships. Referrals to Third Parties The Adviser does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Other Compensation The Adviser may receive certain benefits from recommended broker-dealer/custodians. These benefits do not 18  depend on the amount of transactions we direct to the broker-dealer/custodian. These benefits may include: A dedicated trading desk that services our clients, a dedicated service group and an account services manager dedicated to our accounts, access to a real time order matching system, ability to block client trades, electronic download of trades, balances and positions in the broker-dealer/custodian's portfolio management software, access to an electronic interface with broker- dealer/custodian's software, duplicate and batched client statements, confirmations and year-end summaries, and the ability to have advisory fees directly debited from client accounts (in accordance with federal and state requirements.) Products & Services Available to Us from Schwab Schwab Advisor Services is Schwab’s business serving independent investment advisory firms like ours. They provide us and our clients with access to its institutional brokerage – trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis, at no charge to advisors. Services that Benefit Client Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit clients or their account(s). Services that May Not Directly Benefit Clients Schwab also makes available to us other products and services that benefit us but may not directly benefit the client or their account(s). These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • provides access to client account data (such as duplicate trade confirmations and account statements); facilitates trade execution and allocate aggregated trade orders for multiple client accounts; • • provides pricing and other market data; facilitates payment of our fees from our clients’ accounts; and • assists with back-office functions, recordkeeping and client reporting. • Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: educational conferences and events • technology, compliance, legal, and business consulting; • • publications and conferences on practice management and business succession; and access to employee benefits providers, human capital consultants and insurance providers. • Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Irrespective of direct or indirect benefits to our client through Schwab, we strive to enhance the client’s experience, help reach their goals and put their interests before that of our Firm or its associated persons. 19  Financial Information The Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, has never filed for bankruptcy and is not aware of any financial condition that is expected to affect its ability to manage client accounts. 20 

Item 1 – Cover Sheet Vineyard Wealth Advisors Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) PO Box 675285 Rancho Santa Fe, CA 92067 (612) 860-8855 www.vineyardwealthadvisors.com March 31, 2026 This brochure provides information about the qualifications and business practices of Vineyard Wealth Advisors, LLC. If you have any questions about the contents of this brochure, please contact us at by telephone at (612) 860- 8855, or by email at info@vineyardwealthadvisors.com . Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729- 4222. The information in this Brochure has not been approved or verified by the SEC or any state securities authority. Nothing in this document is to be construed as a recommendation or an endorsement by the SEC or any state securities authority or an offer of securities; refer to the actual investment offering and related legal documentation for complete disclosures. Please note that registration as an investment adviser does not imply a certain level of skill or training. An adviser's written and oral communications provide information to determine whether to retain the adviser's services. This Brochure is on file with the appropriate regulatory authorities as Federal and state regulations require. Additional information about Vineyard Wealth Advisors, LLC and Integrated Advisors Network, LLC is also available on the SEC's website at www.adviserinfo.sec.gov. (Click on the link, select "Investment Adviser- Firm," and type in our firm name or CRD #171991. Results will provide you with all firm disclosure brochures.)  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Frm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov 3  Item 3 – Table of Contents Item 1 – Cover Sheet ........................................................................................................................................... 1 Item 2 – Material Changes ................................................................................................................................... 2 Item 3 – Table of Contents ................................................................................................................................... 4 Item 4 – Advisory Business ................................................................................................................................. 5 Item 6 – Performance Fees ................................................................................................................................. 20 Item 7 – Types of Clients ................................................................................................................................... 20 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................................... 20 Item 9 – Disciplinary Information ...................................................................................................................... 35 Item 10 – Other Financial Industry Activities and Affiliations ............................................................................ 35 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................... 37 Item 12 – Brokerage Practices............................................................................................................................ 38 Item 13 – Review of Accounts ........................................................................................................................... 43 Item 14 – Client Referrals and Other Compensation ........................................................................................... 45 Item 15 - Custody .............................................................................................................................................. 46 Item 16 – Investment Discretion ........................................................................................................................ 46 Item 17 – Voting Client Securities ..................................................................................................................... 48 Item 18 – Financial Information ......................................................................................................................... 48 4  Item 4 – Advisory Business Vineyard Wealth Advisors LLC is a dba of Integrated Advisors Network LLC, hereinafter “the Adviser” or “Vineyard Wealth”. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser (such registration does not imply that the Adviser has attained a certain level of skill or training). Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services The Firm is a fee-only investment management and financial planning firm. Integrated does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The investment management services are provided through separately managed accounts for each client. The Adviser does not act as a custodian of client assets, and the client always maintains asset control. The Adviser has discretion of client accounts and places trades for clients under a limited power of attorney. Vineyard Wealth is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Clark Richard is an Investment Adviser Representative(s) (“IAR(s)”) of Integrated Advisors Network, LLC. The Adviser provides investment services, also known as asset management services. Also, on more than an occasional basis, the Adviser may furnish advice to clients on matters not involving securities, such as financial 5  planning matters. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS"), plan or other report to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable 6  expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income and Security Act ("ERISA") and regulations under the Internal Revenue Conduct of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Code Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is compensated creates conflicts with your interests, so we operate under a special rule that requires us to act 7  in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). interest. - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: such as employer securities or previously closed funds. Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, - - 2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: If you are interested in investing only in mutual funds, you should understand the cost - 8  structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 72. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) 9  Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third-Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Advisor Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet 10  Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: 11  Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Vineyard Wealth through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Vineyard Wealth may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. There is an inherent conflict of interest for Vineyard Wealth whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Vineyard Wealth or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither 13  Adviser nor Integrated do not make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of Vineyard Wealth. Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's s recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Educational Seminars & Workshops Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to effect the transaction through Integrated, its Adviser Representatives, Associates, or any other third party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. 14  Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions 15  Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. 16  In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Assets Under Management Account Type Discretionary Non-Discretionary Total $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Vineyard Wealth’s Form ADV Part 2A Brochure, the applicable Adviser Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management The Adviser bases its fees on a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance therefore at termination any unearned fees as determined on a pro rata basis for the portion of the quarter completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Adviser and fees for comparable services may be available from other sources. In addition, the Adviser may have arrangements in place with other management personnel and affiliates through which profits are split per agreed upon terms. Fees for investment management generally range from 1.50% to 2.50% based on household asset holdings, investment program selected. The fees may include a fee paid to third-party managers that range from 0.18% - 1.00% that is included in the overall management fee. The third-party manager may offer their 17  services as part of a WRAP program. Financial Planning The fee for a financial plan is predicated upon the facts known at the start of the engagement. The fee range is $1,500 to $5,000 and is negotiable. Since financial planning is a discovery process, situations occur wherein the client is unaware of certain financial exposures or predicaments. In the event that the client’s situation is substantially different than disclosed at the initial meeting, a revised fee will be provided for mutual agreement. The client must approve the change of scope in advance of the additional work being performed when a fee increase is necessary. After delivery of a financial plan, future face-to-face meetings may be scheduled as necessary for up to one month. Follow-on implementation work is billed separately at the rate of $250 per hour. Fee Billing Investment management fees are billed quarterly, in advance, meaning that we invoice you before the three-month billing period has begun. Payment in full is expected upon invoice presentation. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) The client’s custodian will deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The clients of Vineyard Wealth will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Vineyard Wealth’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that Vineyard Wealth’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers 18  as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in 19  writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients The Adviser generally provides investment advice to individuals, pension and profit-sharing plans, trusts, estates, or charitable organizations, corporations or business entities. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser generally requires that the client represents and warrants that the value of their account initially is at least $50,000. At the Adviser’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss 20  Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Inverse ETF – Inverse ETFs are investment products designed to provide returns that are the opposite of the performance of a stated market index or benchmark on a daily basis. Advisers may use ETFs on a limited, short- term, or tactical basis to manage market exposure or express short-term market views. Risk: Inverse ETFs reset daily and are subject to compounding effects, which may cause performance over periods longer than one 21  trading day to differ materially from the inverse of the performance of the underlying index. These investments involve heightened risk, including increased volatility, tracking error, and the potential for rapid or significant losses, and are generally not appropriate for long‑term investment strategies. Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Pooled Investment Vehicles and Alternative Allocations – In connection with client portfolios that obtain exposure to alternative investments through pooled investment vehicles, the Adviser relies on investment selection, allocation methodologies, and portfolio construction processes implemented at the fund level by the applicable fund sponsor or manager, which may include the use of proprietary or third-party models. The Adviser does not independently construct, control, or replicate such models and does not manage the day-to-day investment decisions of the pooled investment vehicle. As a result, the Adviser’s ability to influence investment outcomes within these vehicles is limited, and performance is dependent on the methodologies, assumptions, and risk management practices employed by the fund sponsor or manager. Risk: Investments in pooled investment vehicles that utilize proprietary or third-party models involve additional risks, including the risk that model assumptions, data inputs, or methodologies may be incorrect, incomplete, or fail to account for changing market conditions. Because the Adviser does not control or independently validate such models and has limited influence over fund-level investment decisions, clients may experience significant losses, limited liquidity, or outcomes that differ materially from expectations based on traditional asset allocation or risk management approaches. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine 22  investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. 23  Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign 24  fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their 25  portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. 26  Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend 27  to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. The Adviser may utilize inverse ETFs in limited circumstances as part of a short‑term or tactical investment strategy. Inverse ETFs are designed to provide investment results that are the inverse of the performance of a stated index on a daily basis. Because inverse ETFs reset daily, their performance over periods longer than one trading day may differ materially from the inverse of the index’s performance over the same period due to compounding effects. These products involve additional risks, including increased volatility, tracking error, and the potential for significant losses, and are generally not appropriate for long‑term investment strategies. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S. Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to 28  buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock 29  dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, 30  stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, 31  and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: 32  - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. 33  Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. 34  Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Vineyard Wealth. Integrated is an independent registered investment adviser that provides only investment advisory services. Integrated does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), insurance company or agency, 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. 35  Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Sub-Advisory Services to Third-Party Managers VWA has entered into written agreements with certain unaffiliated third-party investment advisers to serve as a sub-adviser and provide Investment Management Services to the third-party advisers' clients. Under these sub- advisory arrangements, each third-party investment adviser is responsible for working with its clients to select the appropriate strategy for investment. VWA manages the clients' designated assets based on the respective selected investment strategy. (Please refer to Item 5: Fees & Compensation for additional information.) Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since certain IARs sold an ownership or financial interest in VGA or a VGA-affiliated entity and may have a financial incentive to submit advisory clients to specific companies, strategies, programs, or services over others due to compensation received or other economic benefits in connection with such relationships, rather than client need. 36  The Adviser addresses these conflicts of interest by requiring Associates to always act in each client’s best interest when making recommendations and to fully disclose such relationships prior to or at the time of any recommendation. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid or received before transaction execution. When acting in this capacity, the firm’s policy requires Associates to communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser, or under any Integrated Investment Management Agreement. Clients are under no obligation to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered, including VGA-related strategies or services. Clients may obtain similar advisory services from other advisers or unaffiliated providers. The ultimate decision to accept any recommendation and retain products or services remains at the client’s sole discretion. Additional details regarding how VGA and the Adviser identify, disclose, and mitigate conflicts of interest are set forth in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics (“Code”). A copy of the Code is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because 37  the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- 38  dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and 39  client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry 40  and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest 41  in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products 42  and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are 43  conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. 44  As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated and/or Adviser has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. 45  Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw any money, securities, or other property from any client custodial account in the client's name or otherwise. However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's 46  conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” 47  as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. 48  While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. Disciplinary Disclosures Certain of Integrated's financial professionals have legal or disciplinary histories to disclose. Please visit the United States Securities and Exchange Commission's ("SEC") website at www.adviserinfo.sec.gov for a free and simple search tool to research Integrated and its financial professionals, management members, officers, and firm 49  principals. 50 

Item 1 – Cover Sheet Vineyard Asset Management, LLC Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 3812 S. Fremont Ave. Springfield, MO 65804 (417) 881-7100 www.vineyardasset.com March 31, 2026 This brochure provides information about the qualifications and business practices of Vineyard Asset Management, LLC. If you have any questions about the contents of this brochure, please contact us at by telephone at (417) 881-7100, or by email at info@vineyardasset.com . Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729- 4222. The information in this Brochure has not been approved or verified by the SEC or any state securities authority. Nothing in this document is to be construed as a recommendation or an endorsement by the SEC or any state securities authority or an offer of securities; refer to the actual investment offering and related legal documentation for complete disclosures. Please note that registration as an investment adviser does not imply a certain level of skill or training. An adviser's written and oral communications provide information to determine whether to retain the adviser's services. This Brochure is on file with the appropriate regulatory authorities as Federal and state regulations require. Additional information about Vineyard Asset Management, LLC and Integrated Advisors Network, LLC is also available on the SEC's website at www.adviserinfo.sec.gov. (Click on the link, select "Investment Adviser- Firm," and type in our firm name or CRD #171991. Results will provide you with all firm disclosure brochures.)  Item 2 – Material Changes In this Item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ................................................................................................................................................1 Item 2 – Material Changes .......................................................................................................................................2 Item 3 – Table of Contents .......................................................................................................................................4 Item 4 – Advisory Business ......................................................................................................................................5 Item 5 – Fees and Compensation ........................................................................................................................... 17 Item 6 – Performance Fees ..................................................................................................................................... 21 Item 7 – Types of Clients ....................................................................................................................................... 21 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................................ 22 Item 9 – Disciplinary Information .......................................................................................................................... 35 Item 10 – Other Financial Industry Activities and Affiliations .............................................................................. 36 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................... 38 Item 12 – Brokerage Practices ................................................................................................................................ 40 Item 13 – Review of Accounts ............................................................................................................................... 45 Item 14 – Client Referrals and Other Compensation ............................................................................................. 46 Item 15 - Custody ................................................................................................................................................... 47 Item 16 – Investment Discretion ............................................................................................................................ 48 Item 17 – Voting Client Securities ......................................................................................................................... 50 Item 18 – Financial Information ............................................................................................................................. 50 4  Item 4 – Advisory Business Vineyard Asset Management, LLC is a dba of Integrated Advisors Network LLC, hereinafter “the Adviser”, “Associate”, “VAM” or “Vineyard Asset”. Integrated Advisors Network, LLC (“Integrated” or “the Firm”) was founded in 2015 and is an SEC registered investment adviser (such registration does not imply that the Adviser has attained a certain level of skill or training). Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. VAM is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Ben Newhouse, John Newhouse, Jennifer Newhouse, Bert Demicell, and Scott Hall are Investment Adviser Representatives (“IARs”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, 5  and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in 6  selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income Security Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Conduct Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: 7  Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best interest. - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. - - 2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the - 8  costs of those share classes compare with those available in an IRA. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 72. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) 9  Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third-Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Advisor Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) 10  Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. 11  The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or indexed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party 12  investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated nor the Adviser invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning VAM through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. VAM may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. 13  There is an inherent conflict of interest for VAM whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. VAM or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of VAM. Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Educational Seminars & Workshops Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. (See Item 10: Other Financial Industry Activities & Affiliations.) Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to effect the transaction through Integrated, its Adviser Representatives, Associates, or any other third 14  party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Corporate and/or municipal debt securities • Digital Assets / Bitcoin • Equities (stocks) • Exchange-traded funds (“ETFs”) • Investment company securities – including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities • Options contracts (including limited use for hedging or income strategies, where appropriate) • U.S. government securities • Warrants Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. 15  Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. 16  Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Vineyard Asset’s Form ADV Part 2A Brochure, the applicable Adviser Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management Integrated/the Adviser provides investment management and supervisory services on a fee-only basis based on the value of the assets to be managed, the work to be provided, and the complexity of their situation. Investment management and supervisory services require a minimum portfolio value of $50,000. If engaged, fees range from 1.5% to 2.5% based on household asset holdings, calculated and billed consistent with the Adviser’s disclosure documents and each client’s contracts’ compensation arrangements. Individual client account fees will vary depending on the selected Program’s investment options and the fee schedule of each Integrated advisory group’s practices. However, in all cases, the Advisor Representative's advisory 17  practices must ensure that the advisory fees they assess clients are accurate, up-to-date, and aligned with disclosures, up to the maximum annual rates. (Note: Lower fees for comparable services can sometimes be available from other sources.) Under certain circumstances, advisory services fees are negotiable up to the maximum annual rates listed herein, subject to certain limitations and approval by the Adviser. The Adviser, in its sole discretion, may charge lesser fees or choose to reduce or waive minimum fees for services based upon specific criteria such as a pre-existing financial planning client, anticipated future earning capacity, expected additional assets, the amount of client assets under management, related accounts, account composition, client negotiations, and pro bono activities, among others. At the Adviser’s discretion, certain accounts for members of a client's family or otherwise may be assessed fees based on the total balance of all accounts. Integrated/VAM will only accept clients with less than the minimum portfolio size if, in the Adviser’s opinion, the smaller portfolio size will not cause a substantial increase in investment risk beyond the client's identified risk tolerance. According to the selected advisory services, final fee structures will be reflected in each client's written Agreement. Integrated/the Adviser believes that the charges and fees offered are competitive with alternative programs available through other firms that may provide a similar range of services; however, lower fees for comparable services, at times, may be available from other sources. While the Adviser seeks to facilitate advantageous agreements for clients, to the extent fees are negotiable, some clients may pay higher (more >) or lower fees (< less) than other clients for services depending on factors such as account total assets under management, the number of related investment accounts, inception date, or other considerations, than if they had contracted directly with another provider. In all cases, clients are responsible for any tax liabilities that result from any transactions. Fee Billing Integrated’s annual investment management and supervisory services fees are billed quarterly in advance according to the client’s Agreement. Clients may have their fees directly debited from the account held at their custodian of record or billed. Integrated will not access client funds for fees without written client consent. Clients who wish to have their fees directly debited will authorize Integrated in writing to deduct any advisory fees due from their custodial account directly and provide their custodian with authorization to deduct such amounts when due and remit them straight to Integrated. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing, a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. 18  Clients who wish to be billed by Integrated for their advisory services fees will authorize this form of payment in writing on their advisory Agreement and request that Integrated invoice them directly monthly or quarterly for any fees due. Clients will then make fee payments to Integrated by separate check or credit card within 45 days of invoice receipt. Under no circumstance will any Integrated advisory fees be deducted from amounts they hold within their custodial account(s). (See Item: 15: Custody for additional details.) ERISA - Retirement & Employee Benefit Plan Services ERISA - retirement and employee benefit plan services fees are billed and payable according to the preceding investment management and supervisory services schedules. Account additions, withdrawals and terminations also follow the same procedures. Clients should refer to their Agreement for complete details. Financial Planning Services Fees Financial planning services fees are predicated upon the facts known at the start of the engagement. The minimum annual flat-rate fee for financial planning is $500 (or $125 each quarter if paid four times a year vs. annually). Based on the client's services, fees can range higher to engage with Integrated as defined in each client's written and executed Financial Planning Agreement. At Integrated/the Adviser’s discretion, limited services are offered at a discounted rate. Since financial planning is a discovery process, situations occur wherein the client is unaware of specific financial exposures or predicaments. If the client's situation differs substantially from what was disclosed at the initial meeting, a revised fee will be provided for a mutual agreement. Agreements may be amended only by the client and Integrated/the Adviser’s mutual written consent. Ultimately, fees will be determined at the discretion of the advisor assigned to the account based on the required resources and plan complexity. If a financial planning services fee increase is necessary, the client must approve the scope change before any additional work is performed. Financial planning fees are billed in advance when the Financial Planning Agreement is executed and payable within ten (10) days of invoice presentation. Clients may directly authorize deducting these fees from their custodial account or pay them via check or credit card. After plan delivery, future fact-to-face meetings and follow-up implementation work may be scheduled as necessary free of charge for up to 3 months. The client will receive a fee refund upon delivery of the completed financial plan. Alternatively, Integrated/the Adviser may require the client to pay an initial retainer of 50% of the estimated financial planning fee before any services are rendered. The remaining balance is payable upon completion of the contracted services. Integrated/the Adviser are not responsible for any additional fees, commissions, expenses, or charges related to the transfer of assets from any other investment manager or advisor, real estate transactions or other expenses associated with real property transactions, or fees related to any major purchases or other transactions the client effects. The client's responsibility is to remit payment for the administrative expenses and fees due to the TPMs by Integrated/VAM for the financial plan and timely resolve such additional fees, commissions, expenses, or charges. Integrated Fee Disclosure The clients of VAM will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. VAM’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that VAM’s fees are the lowest available for similar services. 19  Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. 20  The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients The Adviser generally provides investment advice to individuals, pension and profit-sharing plans, trusts, estates, or charitable organizations, corporations or business entities. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums To open and maintain a portfolio management account, the Adviser generally requires that the client represents and warrants that the value of their account initially is at least $50,000. At the Adviser’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. 21  Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally 22  assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment 23  products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be 24  adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. 25  Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, 26  currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. 27  Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests 28  in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. 29  Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index 30  specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined 31  price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. 32  Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call 33  options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. 34  Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. 35  Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of VAM. Integrated is an independent registered investment adviser that provides only investment advisory services. Integrated does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. an investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. 36  Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Registered Representative of Broker-Dealer Integrated is not registered and does not intend to register as a broker-dealer. Still, in connection with their approved outside business activities, some Integrated and VAM Associates can be Registered Representatives (“RRs”) of non-affiliated broker-dealers and Members of FINRA/SIPC. Associates with these unaffiliated broker-dealers can provide brokerage services as an RR of the unaffiliated broker-dealer firm. When acting in the capacity of an RR, the Associates will sell, for commissions, general securities products and will receive commission-based compensation in connection with the purchase and sale of such securities, including 12b-1 fees for the sale of investment company products. Associates of Vineyard Asset offer brokerage products through their unaffiliated broker-dealer. They are not acting in a brokerage capacity or on behalf of Integrated concerning the services provided under our Agreement(s). Integrated is not involved in the transaction and receives no compensation for the Associate's outside business activity. Associates who provide brokerage services through unaffiliated broker-dealers are independent contractors of such companies. Any compensation earned by these individuals in their capacities as RRs is separate, in addition to, and not related to our advisory fees or Agreement to provide advisory services. Clients are under no obligation to use the firm's Associates’ services in this different capacity as broker-dealer employees. Insurance Services Some Associates are licensed as independent insurance agents through non-affiliated insurance companies offering fixed, fixed index, variable annuities, life, or long-term care universal life or other insurance products, and insurance services clients may decide to use VAM for investment advisory services. In these capacities, Advisor Representatives can recommend to firm clients and receive separate, yet customary, commission compensation, including bonuses and trail commissions, resulting from the purchases and sales of these products from the insurance agencies with whom they are presently or with whom they may become appointed in the future in addition to their compensation from the Adviser. Such commissions and advisory fees are separate from the firm's advisory fees and Agreements, and clients are under no obligation, contractually or otherwise, to purchase insurance products or receive investment advice through insurance-licensed Associates in their capacities as insurance agents or Advisor Representatives. Tax Preparation Services Advisory clients may choose to use non-affiliated independent tax preparation services. And clients of the tax preparation providers may decide to use Integrated/VAM for financial planning and/or investment advisory 37  services. Although Associates will make clients aware of the availability of tax preparation services, advisory clients are not required to utilize such services. Other Business Relationships VAM uses third-party resources to help run its business and provide services to its clients, mostly back-office related. The Adviser sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-added providers to service clients. While VAM has developed a network of professionals - accountants, lawyers, and otherwise, neither the Adviser nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since VAM’s Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. VAM addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of the firm, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, VAM’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of VAM, the investment adviser or under any VAM Advisory Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how VAM mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics (“Code”). A copy of our Code is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients 38  and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. 39  To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and • • 40  as discussed below, the availability of other products and services that benefit us. • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client 41  accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. 42  Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. 43  While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account 44  to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly. Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate 45  information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals VAM receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals VAM has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated/VAM will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers 46  Act Rules. Integrated/VAM will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. VAM is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, the Adviser will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. VAM does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated/VAM. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although VAM is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated/VAM is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, Integrated does not compensate any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by VAM and its Associates, as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize VAM or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated/VAM addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated/VAM makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw any money, securities, or other property from any client custodial account in the client's name or otherwise. However, Integrated is deemed to have 47  custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. 48  Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with 49  trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. 50  Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 51 

Item 1 – Cover Sheet Yorkshire Wealth Management Form ADV Part 2A – Firm Brochure (CRD #171991 / SEC #801-96203) 16935 W. Bernardo Court, Suite 170 San Diego, CA 92127 (858) 798-5616 yorkshirewealthmanagement.com March 31, 2026 This brochure provides information about the qualifications and business practices of Yorkshire Wealth Management, Inc. If you have any questions about the contents of this brochure, please contact us at (858) 798- 5616, or by email at douglas.shultz@ywmgmt.com Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729- 4222 The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfo@sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet ........................................................................................................................................... 1 Item 2 – Material Changes ................................................................................................................................... 2 Item 3 – Table of Contents ................................................................................................................................... 4 Item 4 – Advisor Business ................................................................................................................................... 5 Item 5 – Fees and Compensation ........................................................................................................................ 18 Item 6 – Performance Fees ................................................................................................................................. 21 Item 7 – Types of Clients ................................................................................................................................... 21 Item 8- Methods of Analysis, Investment Strategies and Risk of Loss ................................................................ 22 Item 9 – Disciplinary Information ...................................................................................................................... 35 Item 10 – Other Financial Industry Activities and Affiliations ............................................................................ 36 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................... 38 Item 12 – Brokerage Practices............................................................................................................................ 39 Item 13 – Review of Accounts ........................................................................................................................... 44 Item 14 – Client Referrals and Other Compensation ........................................................................................... 44 Item 15 - Custody .............................................................................................................................................. 47 Item 16 – Investment Discretion ........................................................................................................................ 48 Item 17 – Voting Client Securities ..................................................................................................................... 49 Item 18 – Financial Information ......................................................................................................................... 50 4  Item 4 – Advisor Business Description of Firm Yorkshire Wealth Management Inc. is a dba of the registered entity Integrated Advisors Network, LLC, collectively hereinafter “the Adviser” or “Yorkshire Wealth”. Integrated Advisors Network, LLC (“Integrated”) was founded in 2015 and is an SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services The Firm is a fee-only investment management and financial planning firm. Integrated does not sell securities on a commission basis. However, there may be some associated persons who are in other fields where they receive commissions as compensation. The investment management services are provided through separately managed accounts for each client. The Adviser does not act as a custodian of client assets, and the client always maintains asset control. The Adviser has discretion of client accounts and places trades for clients under a limited power of attorney. Yorkshire Wealth is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Phil Bell and Doug Shultz are Investment Adviser Representatives (“IARs”) of Integrated Advisors Network, LLC. The Adviser provides investment services, also known as asset management services. Also, on more than an occasional basis, the Adviser may furnish advice to clients on matters not involving securities, such as financial planning matters. 5  Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio 6  strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement and IPS. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income and Securities Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Code Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is compensated creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - 7  Never put our financial interests ahead of yours when making recommendations (give loyal advice). interest. - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. Neither Integrated nor Adviser will receive no compensation if a client or a prospective client receives a recommendation to leave their plan assets with their old employer.” IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: such as employer securities or previously closed funds. Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, - - 2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. 8  You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 72. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 2. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of 9  registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub-advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co-investment adviser to advise and/or administer clients' accounts. Integrated and/or Adviser will refer only those individuals or entities suitable for its MAS Program services. MAS Program advisers are subject to review by Integrated's standards for inclusion and subject to future change from time to time. Integrated Adviser Representatives act in a Promoter capacity when referring MAS Program clients for this service. Integrated's role is to verify that clients are appropriate to become MAS Program clients, determine if the potential referred client has assets to invest, confirm the client has a minimum understanding of financial investing, and aid in their understanding of the referred manager's services and advisory contract (the “MAS Program Services Agreement” or “Program Agreement”). Any additional solicitation information provided by Integrated to a referred investor will be prepared and supplied to Integrated for distribution by the referred third-party manager. These materials may include (1) written presentations or oral statements that do not purport to meet the objectives or needs of the specific investor, (2) statistical information containing no expressions of opinions as to the investment merits of particular securities, or (3) other general advisory services. Clients wishing to engage in this service will execute two (2) advisory account management agreements. First, an Investment Management Agreement with Adviser and an additional but separate MAS Program Services Agreement with the referred manager. As such, the client, as detailed within each referred manager’s Program Agreement, will enter an investment advisory, management, or other investment-related arrangements with their selected referred manager. The client, who will sign an acknowledgment receipt, will receive copies of all material operative documentation and disclosures related to such arrangements detailing the nature of the relationship, compensation to Integrated and the TPM, and other general terms of the referred TPM’s Program. Integrated does not maintain the authority to accept any client on behalf of any referred TPM, and referred managers are not responsible for accepting any prospective investor (and possible future client) referred to them by Integrated. Each manager has the right to reject any referred client for any reason or no reason at all. In selecting a referred manager, the client is responsible for understanding the fee and Program Agreement they are executing with the TPM. Referred clients typically pay the TPM manager a fee between 0.10 and 2.95%, not including referral fees, which vary based on the executed Promoter agreement. Integrated’s referral payout is in addition to client fees. Integrated or Adviser will receive revenue from any fees paid when acting in this capacity. Fees shared will not exceed any limit imposed by any regulatory agency. Clients should refer to their TPM Agreement for exact details and amounts. Integrated, Adviser and referred MAS Program managers are separate, non-affiliated entities. (See Item 5: Fees & Compensation for additional information on Integrated’s advisory fees for this service, Item 14: Client Referrals & Other Compensation for further information on Promoter relationships, and the independent third-party manager’s Program Agreement and separate Program prospectus and related disclosure documents for complete details on any fees charged by the independent third-party advisers providing this service.) Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Adviser Representative and/or client. (See Item 16: Investment Discretion of the referred manager’s Form ADV 2A for additional information on this topic.) For all Programs, the client and their Adviser Representative will compile pertinent financial and demographic information to develop an investment program that strives to meet the client’s goals and objectives. According to the TPM's Agreement, clients may impose reasonable investment restrictions on managing the assets in their 10  accounts. (Note: For detailed information about Program information and the investment strategies employed in a Program account, please refer to the referred manager’s ADV 2, under Item 8 - Methods of Analysis, Investment Strategies & Risk of Loss.) Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. 11  EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or index-ed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs 12  administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to 13  recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated does not invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning Yorkshire Wealth through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Yorkshire Wealth may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. There is an inherent conflict of interest for Yorkshire Wealth whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. Yorkshire Wealth or its associated persons may receive compensation for financial planning and the provision of investment management services and/or the sale of insurance and other products and services. Neither Adviser nor Integrated do not make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of Yorkshire Wealth. Wealth Coaching, Second Opinions & Financial Analysis Fees Yorkshire Wealth may provide coaching services that typically do not include investment advisory or management services, financial planning services, nor the review or monitoring of a client’s investment portfolio. The Adviser may recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Adviser. If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. It remains the client’s responsibility to promptly notify the Adviser if there is ever any change in his/her/its situation for the purpose of reviewing/evaluating/revising the Adviser’s previous recommendations and/or services. 14  Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's s recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Educational Seminars & Workshops Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. (See Item 10: Other Financial Industry Activities & Affiliations.) Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to effect the transaction through Integrated, its Adviser Representatives, Associates, or any other third party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or 15  services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Equities (stocks). • Corporate debt securities. • Digital Assets / Bitcoin • Exchange-traded funds (“ETFs”). • Investment company securities - variable life insurance, variable annuities, and mutual fund shares (no- load/ low-load). • Warrants. • U.S. government securities. Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. 16  Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Generally, Integrated considers its Managed Account Solutions (“MAS”) Program services a Wrap Fee Program. Integrated receives a portion of the wrap fee for the services we provide. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. Assignment of Investment Management Agreements Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. 17  In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Assets Under Management Account Type Discretionary Non-Discretionary Total $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of Yorkshire Wealth’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management The Adviser bases its range of fees as a percentage of assets under management. Although the Advisory Service Agreement is an ongoing agreement and constant adjustments are required, the length of service to the client is at the client’s discretion. The client or the investment manager may terminate an Agreement by written notice to the other party. Fees are collected in advance therefore at termination any unearned fees as determined on a pro rata basis for the portion of the month completed shall be refunded to the client. The investment management fees are negotiable at the sole discretion of the Adviser and fees for comparable services may be available from other sources. The Adviser’s Fee generally can range from .85% through 1.25%, depending upon the passive or active nature and size of the portfolio. Assets Under Management Annual Fee Up to $499,999.99 1.25% $5,000,000 to $999,999.99 1.00% 18  $1,000,000 to $1,749,999.99 0.85% $1,750,000.00 + Negotiable Financial Planning Fees Financial Planning for clients, which includes complex situations, is provided under a fixed fee arrangement agreed upon at the first meeting and billed monthly. These services can either be provided based on a range of $250 - $4000 fixed fee or Yorkshire Wealth may charge a $250 hourly fee for consultation and planning. FINANCIAL PLANNING Portfolio/Investments Review $250 Retirement Planning $250 Financial Plan Standard $2,000 Financial Plan Advanced $4,000 Hourly Consulting and Planning $250 per hour Fee Billing Investment management fees will be billed monthly in advance. Advisory fees are billed and deducted at 1/12th the annual rate. Payment in full is expected upon invoice presentation. Account values are based upon pricing information supplied by the client’s third-party qualified custodians, where their accounts are held. Fees are deducted from the client account to facilitate billing as authorized by the investment management agreement. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Integrated Fee Disclosure The clients of Yorkshire Wealth will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. 19  Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. Yorkshire Wealth fees may be higher or lower than other advisory groups at Integrated and there is no representation that Yorkshire Wealth fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional 20  important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. Item 7 – Types of Clients Description The Adviser provides services to institutions, individuals, high net worth individuals, pension and profit-sharing plans, trusts, estates or charitable organizations, and corporations or other business entities directly. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. 21  Account Minimums To open and maintain a portfolio management account, the Adviser generally requires that the client represents and warrants that the value of their account initially is at least $200,000. At the Adviser’s discretion, we may accept clients with smaller accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8- Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. 22  Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. 23  Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: 24  (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with 25  debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to 26  higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently 27  and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are 28  professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or 29  dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends 30  mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured 31  products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability 32  to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such 33  risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could 34  lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or to formulate the specific investment advice provided to clients. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Information Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. 35  Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of Yorkshire Wealth. Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's 36  referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Integrated can also serve as Promoter to the third-party money managers it engages for its Managed Account Solutions (“MAS”) Program services for advisory, administrative, and/or technological services. In this capacity, the Adviser will introduce clients for whom the referred manager's services are suitable and appropriate. In connection with such relationships, Promoter fees can range from 0% to 50% and vary based on the executed Solicitor Agreement. Fees shared will not exceed any limit imposed by any regulatory agency. Clients should refer to their TPM Agreement for exact details and amounts. (Please see Item 14: Client Referrals & Other Compensation for additional details.) Apart from our clients' fees, we do not receive any other economic benefits, including sales awards or prizes. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct - and sometimes act - as a Promoter while referring prospective clients or clients to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Referred clients will enter a separate Program Agreement with the referred manager and receive the manager's disclosure documents, which they are encouraged to read. The relationship - including any conflicts of interest involving providing advice, service, or account management style - will be disclosed in each contract between Integrated, the third-party money managers, and the client. Integrated reserves the right to add or delete managers as deemed necessary. Clients should contact Integrated directly for a current list of referred managers under this service. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Insurance Affiliations Yorkshire Wealth and/or certain associated persons of Yorkshire Wealth may sell insurance products to advisory clients. Some Associates are licensed as independent insurance agents through non-affiliated insurance companies offering fixed, fixed index, variable annuities, life, or long-term care universal life or other insurance products, and insurance services clients may decide to use Integrated for financial planning or investment advisory services. In these capacities, Integrated Adviser Representatives can recommend to firm clients and receive separate, yet customary, commission compensation, including bonuses and trail commissions, resulting from the purchases and sales of these products from the insurance agencies with whom they are presently or with whom they may become appointed in the future in addition to their compensation from Integrated. Such commissions and advisory fees are separate from the firm's advisory fees and Agreements, and clients are under no obligation, contractually or otherwise, to purchase insurance products or receive investment advice through insurance-licensed Associates in 37  their capacities as insurance agents and/or Integrated Adviser Representatives. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled 38  investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Trade Errors If a trading error occurs in your account, our policy is to restore our client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Item 12 – Brokerage Practices 39  Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified 40  custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade 41  execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory 42  custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such 43  directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or 44  political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program 45  Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends 46  clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw any money, securities, or other property from any client custodial account in the client's name or otherwise. However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires 47  the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions 48  on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. 49  While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. Disciplinary Disclosures Certain of Integrated's financial professionals have legal or disciplinary histories to disclose. Please visit the United States Securities and Exchange Commission's ("SEC") website at www.adviserinfo.sec.gov for a free and simple 50  search tool to research Integrated and its financial professionals, management members, officers, and firm principals. 51 

ZIMMERMAN WEALTH ADVISORY GROUP LLC FINANCIAL PLANNING • PORTFOLIO MANAGEMENT • CONSULTING Item 1 – Cover Sheet Zimmerman Wealth Advisory Group, LLC. Form ADV Part 2A – Firm Brochure 2950 Buskirk Ave, Suite 300 Walnut Creek, CA 94597 Telephone: (925) 698-3683 www.ZimWAGs.com March 31, 2026 This brochure provides information about the qualifications and business practices of Zimmerman Wealth Advisory Group, LLC. If you have any questions about the contents of this brochure, please contact us at (925) 698-3683, or by email at Info@ZimWAGs.com. Alternatively, contact the Chief Compliance Officer of Integrated Advisors Network, Danielle Tyler at compliance@integratedadvisorsnetwork.com or call (855) 729-4222 The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about the Advisor is available on the SEC’s website at www.adviserinfo@sec.gov. Integrated Advisors Network, LLC is a registered investment advisor. Registration with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes In this item, Integrated Advisors Network, LLC ("Integrated" or "the Firm") is required to summarize only those material changes made to this Brochure since our last annual updating amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last annual updating amendment on March 31, 2025, Integrated Advisors Network, LLC has made the following material changes to this Brochure: Item 4: Advisory Business Assets Under Management As of December 31, 2025, the Adviser's total assets under management are $5,522,561,843. The following represents client assets under management by account type: Account Type Discretionary Non-Discretionary Total Assets Under Management $ 5,286,824,594 $ 235,737,249 $ 5,522,561,843 Item 5: Fees & Compensation Bundled Fee Arrangement Clarification Within this section, Integrated clarified that certain independent investment professionals (Investment Advisor Representatives of “DBA” entities) who are affiliated with Integrated may choose to bill client fees using a “bundled” fee arrangement. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. (See Item 5 for details.) Item 9: Disciplinary Information SEC Regulatory Action On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Advisor Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Item 10: Other Financial Industry Activities & Affiliations Item 10 was updated to include additional detail regarding promoter relationships, compensation arrangements, pension consulting, and sub-advisory services. These disclosures clarify potential conflicts of interest and Integrated’s procedures for mitigating such conflicts. (See Item 10 for details.) Clients are encouraged to review the full Brochure and contact us directly with any questions regarding these changes. 2  Full Brochure Availability We may, at any time, amend this document to reflect changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually and as necessary, due to material changes, we will provide clients, either by electronic means or hard copy, with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this for future reference, as it contains essential information concerning our advisory services and business. You can view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either "Integrated Advisors Network, LLC" or CRD #171991. The SEC's website also provides information about any Integrated-affiliated person registered or required to be registered as an Investment Advisor Representative of the firm. You may obtain our current brochure free of charge at www.integratedadvisorsnetwork.com, by emailing compliance@integratedadvisorsnetwork.com, calling 855‑729‑4222, or visiting www.adviserinfo.sec.gov. 3  Item 3 – Table of Contents Item 1 – Cover Sheet.............................................................................................................................. 1 Item 2 – Material Changes ..................................................................................................................... 2 Item 3 – Table of Contents ..................................................................................................................... 4 Item 4 – Advisory Business.................................................................................................................... 5 Item 5 – Fees and Compensation .......................................................................................................... 17 Item 6 – Performance Fees ................................................................................................................... 22 Item 7 – Types of Clients ..................................................................................................................... 22 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................ 22 Item 9 – Disciplinary Action ................................................................................................................ 36 Item 10 – Other Financial Industry Activities and Affiliations .............................................................. 36 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........... 38 Item 12 – Brokerage Practices .............................................................................................................. 38 Item 13 – Review of Accounts ............................................................................................................. 45 Item 14 – Client Referrals and Other Compensation ............................................................................. 46 Item 15 - Custody ................................................................................................................................ 48 Item 16 – Investment Discretion .......................................................................................................... 49 Item 17 – Voting Client Securities ....................................................................................................... 49 Item 18 – Financial Information ........................................................................................................... 51 4  Item 4 – Advisory Business Description of Firm Zimmerman Wealth Advisory Group, LLC, is a dba of the registered entity Integrated Advisors Network LLC, collectively hereinafter as “the Adviser”, “Associate” or “ZWAG LLC”. Integrated Advisors Network, LLC (collectively known hereinafter as “the Firm” or “Integrated”) was founded in 2015 and is an SEC registered investment adviser. Principal Owners of Integrated Advisors Network LLC Integrated Advisors Network, LLC is owned by TX-HI, LLC. The control persons of Integrated are Michael A. Young, President and Managing Partner, Jeffrey J. Groves, Co-Founder, and Linda M. Pix, Co-Founder & Chief Relationship Officer. Integrated serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, the Adviser upholds a duty of loyalty, fairness and good faith towards each client and seeks to mitigate potential conflicts of interest and avoid situations in which one client's interest may conflict with the interests of another. Integrated's advisory services are made available to clients primarily through its investment professionals - individuals associated with the firm as Investment Adviser Representatives (“Adviser Representatives” or “IARs”). Each advisory relationship at Integrated is managed by one or more Adviser Representatives registered with the firm, who serves as the primary point of contact between Integrated and the client. Adviser Representatives collect financial profile information from clients and recommend specific advisory services or programs deemed appropriate for each client’s individual situation, financial circumstances, goals and objectives. Adviser Representatives are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Adviser Representative may or may not recommend certain services, investments, or models depending on the licenses or training obtained; they may transact business or respond to inquiries only in the state(s) in which they are appropriately qualified. (For more information about the investment professionals providing advisory services, clients should refer to their Adviser Representative's Form ADV 2B brochure supplement, the separate disclosure document delivered to them, along with this brochure, before or at the relationship inception. If the client did not receive these items, they should contact their Adviser Representative or Integrated’s Chief Compliance Officer directly at 855.729.4222 for a copy of these essential and informative disclosure documents.) Integrated's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client’s specific financial situation. Types of Advisory Services Integrated is a fee-only investment management and financial planning firm; it does not sell securities on a commission basis. Integrated’s Associates emphasize continuous personal client contact and interaction in providing portfolio management and financial planning services, selection of other advisers (including private fund managers), and educational seminars and workshop services. ZWAG LLC is a dba of Integrated Advisors Network LLC. All advisory services are offered through Integrated Advisors Network LLC. Geoff Zimmerman is an Investment Adviser Representative (“IAR”) of Integrated Advisors Network, LLC. Integrated's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Management Agreement" or "Agreement") that disclose, in substance, the scope of service, contract term, advisory fee - or formula for computing the fee, amount or manner of calculation of any pre-paid fee to be returned to the client in the event of non-performance or contract termination, 5  and type of discretionary power granted to Integrated. Final advisory fee structures – which will range from a percentage of assets under management, hourly charges, fixed fees (other than subscription fees), and performance fees, depending upon the service selected, are documented within the client’s written Agreement. Adviser Representatives are restricted to providing the services and fees specified within each client’s contract, subject to the client's listed objectives, limitations, and restrictions. Contracts must be completed and executed to engage in Integrated's advisory services, and clients may engage the Adviser for additional services at any time. (See Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management styles.) If requested by the client, services of other professionals may be recommended for implementation purposes. Other professionals, such as lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. Clients are under no obligation to engage in any recommended professional's services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Neither Integrated nor the Adviser is a party to the transaction and does not maintain authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any Integrated client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Integrated. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities The Adviser's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their Agreement. Adviser Representatives will rely upon the accuracy of information furnished by the client or on their behalf without further investigation – neither the Adviser nor Integrated will be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify the Adviser in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if previously disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their Agreement or our authority thereunder. The Adviser reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Initial public offerings (IPOs) are not available through Integrated. Asset Management Asset management and supervisory services clients undergo an initial interview and discussion to outline their current financial situation, establish risk tolerance, and determine their investment objectives to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with realistic and measurable goals set based on the disclosed information and objectives to define those goals. The details of the advisory relationship and final advisory fee structure are documented within the client's written Investment Management Agreement. 6  If appropriate for the account type established, Adviser will also create an Investment Policy Statement ("IPS") to aid in selecting a portfolio that matches the client's circumstances. An IPS establishes reasonable expectations, objectives, and guidelines for investing the client's portfolio account assets and sets forth an investment structure detailing permitted account asset classes and allocations. Clients will be assigned to one of several risk profiles with their specific portfolio strategy based on the information gathered and the amount of assets to be managed on their behalf. It is essential to note that an IPS creates the framework for what is intended to be a well-diversified asset mix whose goal is to generate acceptable, long-term returns at a level of risk suitable to the client. An IPS is not a contract and is not to be construed as offering any guarantee. An IPS is an investment philosophy summary intended to guide the client and their Advisor Representative. Clients are ultimately responsible for establishing their investment policy. According to the client's Agreement, custody of client assets will be held by an independent and separate qualified custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account. Other than the standard business practice of deducting management fees from client accounts after receiving the client’s written permission and in other limited circumstances, neither Integrated nor the Adviser maintain physical custody of client funds or securities. Integrated and Adviser primarily recommend that clients maintain all investment management accounts at their preferred custodian unless the client directs otherwise. Adviser will then supervise and direct the account's investments, subject to the objectives, limitations, and restrictions listed in the client's written Agreement and IPS. (See Item 15: Custody and Item 5: Fees & Compensation for additional details.) As account goals and objectives will often change over time, suggestions are made and implemented on an ongoing basis as the client and Adviser Representative review their financial situation and portfolio through regular contact and annual meetings to determine changes in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) ERISA - Retirement & Employee Benefit Plan Services As part of its investment management services, Integrated also offers ERISA - retirement and employee benefit plan services, wherein the Adviser provides investment due diligence, education, and other investment advisory services to clients with employee benefit plans or other retirement accounts for a level fee. Under this service, Integrated or Adviser can provide investment due diligence, education, or other investment advisory services to clients with employee benefit plans or retirement accounts for a level fee. As such, the firm is considered a fiduciary under the Employee Retirement Income and Securities Act ("ERISA") and regulations under the Internal Revenue Code of 1986 and must abide by the Impartial Conduct Standards, as ERISA defines. To comply with the Impartial Code Standards, Integrated or Adviser provides advice to clients based on their best interests and charges no more than reasonable compensation (within the meaning of ERISA Section 408(b)(2) and Internal Revenue Code Section 4975(d)(2)) for such advice. The firm makes no misleading statements about investment transactions, compensation, conflicts of interest, or other matters related to investment decisions and maintains a non-variable compensation structure based on a fixed percentage of asset value or a set fee that does not vary with investment recommendations; instead of commissions or other transaction-based fees. In connection with such accounts, effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: “When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, laws governing retirement accounts. The way Integrated is compensated creates conflicts with your interests, so we operate under a special rule that requires us to act 7  in your best interest and not put our interests ahead of yours. Under this special rule's provisions, we must: Meet a professional standard of care when making investment recommendations (give prudent advice). - Never put our financial interests ahead of yours when making recommendations (give loyal advice). interest. - Avoid misleading statements about conflicts of interest, fees, and investments. Follow policies and procedures designed to ensure that we provide advice that is in your best - - Charge no more than is reasonable for our services. Give you basic information about conflicts of interest. - - Integrated and Adviser benefit financially from the rollover of a client's assets from a retirement account to an account we manage or provide investment advice because the assets increase our assets under management and, in turn, our advisory fees. Integrated's policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to a retirement account subject to our management, they will be charged an asset-based fee as outlined in the Agreement they executed with Adviser. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are under no obligation to have their retirement assets managed by Integrated or Adviser. Neither Integrated nor Adviser will receive no compensation if a client or a prospective client receives a recommendation to leave their plan assets with their old employer.” IRA Rollover Considerations In determining whether to make an IRA rollover to Integrated or Adviser, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors Integrated and Adviser will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of Adviser, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients wishing to participate in this service should carefully consider the costs and benefits of the following: 1. Leaving the funds in the employer's/former employer's plan. 2. Moving the funds to a new employer's retirement plan. 3. Cashing out and taking a taxable distribution from the plan. 4. Rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. Clients contemplating rolling over retirement funds to an IRA for us to manage are encouraged to first speak with their CPA or tax attorney. The following are additional points for client evaluation before making any changes: 1. Determine whether the investment options in your Employer's retirement plan address your needs or whether you might wish to consider other investment types: such as employer securities or previously closed funds. Employer retirement plans generally have a more limited investment menu than IRAs, and Employer retirement plans may have unique investment options not available to the public, - - 2. Consider plan fees - your current plan may have lower fees than Adviser’s fees: 8  If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your Employer's retirement plan and how the costs of those share classes compare with those available in an IRA. - You should understand the various products and services you might take advantage of at an IRA provider and the potential costs. - 3. Adviser’s strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 72. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed at any time; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 2. Your plan may allow you to hire Integrated as the manager and keep the assets titled in the plan name. General Disclosure Regarding ERISA, Retirement & Other Qualified Accounts When establishing ERISA accounts, Integrated will have plan fiduciaries for discretionary accounts, evidence of their authority to retain Integrated's advisory services and appoint Integrated as an "investment manager" within the meaning of Section 3(38) of ERISA for those plan assets that comprise the client's account. The plan fiduciaries will confirm that the services described in Integrated's Agreement are consistent with plan documents and furnish accurate and complete copies of all documents establishing and governing the plan. They will also promptly provide us with a copy of all relevant documents, agree that their selected advisory program is consistent with those documents, and will timely notify us, in writing, of any changes to any of the plan's investment policies, guidelines, restrictions, or other plan documents about the plan’s investments. If the assets in the account constitute only a part of the plan assets, the plan fiduciary will provide us with documentation of any of the plan's investment guidelines or policies that affect the account. As ERISA requires, the client will acknowledge that neither Integrated nor Adviser has responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. The compliance of any recommendation or investment Integrated's Adviser Representatives make with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. The client is responsible for providing us with prompt written notice if any investments made for the account are inconsistent with such guidelines, policies, restrictions, or instructions. Neither Integrated nor Adviser is responsible for plan administration or performing other duties not expressly outlined in the Agreement. Further, the client is responsible for obtaining and maintaining (at their own expense) any insurance or bonds they deem necessary to cover themselves and any of their affiliates, officers, directors, employees, agents or as otherwise required, in connection with Adviser’s Investment Management Agreement. If ERISA or other applicable law demands bonding for the account's assets, Integrated will ensure bonding is in place to satisfy the obligation to cover the Adviser and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. Clients should consult their Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) 9  Managed Account Solutions Program Services As part of its investment management and supervisory services, Integrated retains the ability to select, recommend and provide access, after appropriate due diligence, to independent third-party advisers from a select group of registered investment adviser managers participating in its Managed Account Solutions (“MAS”) Program Services. ZWAG LLC does not use any Managed Account Solutions program services. This service allows clients to establish an account utilizing select Programs developed by third-party managers (collectively referred to as sub- advisers or the “TPMs”) with whom Integrated has entered an agreement to make their services available as a co- investment adviser to advise and/or administer clients' accounts. Through these Programs, the Adviser assists the client with selecting an investment strategy and enrolling the client in a Program sponsored or managed by an unaffiliated third-party portfolio manager (the “Third-Party Manager” or “TPM”). Integrated Advisors Network, LLC (“Integrated”) and the referred Program managers are separate, non-affiliated entities. The client’s account is managed pursuant to the applicable Program documents and disclosures provided by the TPM/platform provider. Clients participating in the Programs are typically required to grant discretionary investment authority to the TPM to manage the assets in accordance with the selected strategy. Clients may impose reasonable investment restrictions as permitted by the applicable Program agreement. Clients who participate in MAS Programs are typically required to grant full discretionary investment authority to the TPM to manage those assets pursuant to the investment strategy selected by their Advisor Representative and/or client. Utilizing Program platform tools, the client’s assets will be allocated among the different options in their Program. The asset allocation and investment options appropriateness for each client will be determined based on their needs and objectives, investment time horizon, risk tolerance and other relevant factors. Specific account management, authority, and any limitations therein will be dictated by the type of Program Agreement the client enters with each TPM and their investment profile, which is then used to select a portfolio that matches their desired investment plan. The referred manager will then observe the client's arrangements in the executed Program Agreement for exact account management and implementation. The client's investor profile will determine any adjustments made. According to the referred manager's review parameters, the TPM will review client accounts within the context of the client's stated investment objectives and guidelines and provide statements and reporting according to the Program Agreement’s provisions. Because the information clients disclose in their investor profile will help determine their recommended allocation strategy, each client is responsible for promptly communicating to their TPM and Integrated all substantive changes in their financial circumstances, investment objectives, or other information considered material to the advisory relationship as they occur. Custody of client assets will be held with the client’s independent and separate qualified custodian, according to the Program Agreement, who will take possession of the cash, securities, and other assets within the client's referred account. The client's relationship with their referred manager's custodian will be governed by a separate custodial/brokerage account agreement entered directly between the client and the custodian. Outside of deducting advisory fees, Integrated will neither have access to the assets nor the income produced from the client's referred- manager custodial account or physical custody of the client's funds or securities. The client will authorize the deduction of any advisory fees due according to the Program Agreement’s provisions and is responsible for all expenses billed by their custodian. Integrated is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other expenses related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. (Please refer to the TPM’s Form ADV 2A, Item 15 - Custody for additional details on custodial practices and note that the broker-dealer/custodian does not provide investment advisory services to the Adviser or the Adviser's clients.) 10  Envestnet Integrated typically recommends Envestnet Portfolio Solutions, Inc. (“EPS,” CRD #109662 / SEC #801-43579) as its preferred MAS Program manager. EPS, an investment adviser registered with the SEC since 1993, provides investment advisory, management, and multi-product online technology services and products to advisers like Integrated and their end clients. EPS also serves institutional clients such as pension or profit-sharing plans, trusts, estates, and corporations and directly provides advisory and research services to firms. EPS is a wholly-owned subsidiary of its parent company, Envestnet, Inc. (NYSE trading symbol, “ENV”), a publicly held company. EPS provides Integrated an extensive range of investment sub-advisory services for use with its clients through its Private Wealth Management programs, including Separately Managed Accounts (“SMA”), ActivePassive Portfolios, Unified Managed Accounts (“UMA”), PMC Multi-Manager Accounts (“PMC MMA”) and Third-Party Fund Strategists (together, the “Programs” and individually a “Program”). Within these programs, specific investment strategies that are prefaced with “PMC” or “Sigma” designate that the investment strategy is a proprietary strategy of EPS or its affiliated investment adviser Envestnet Asset Management (“EAM”), as opposed to the third-party investment strategies also available in the SMA, UMA, MMA and Third-Party Fund Strategists programs. EPS also makes available several services within these programs (as defined within the referred Manager’s ADV 2A), including the PMC Custom Case Design Service, PMC White Label UMA Service, Strategist UMA, Private Wealth Consulting Service (“PWC”), and Manager Outsourced Consulting Services (“Manager OC Services”). EPS offers its services to Integrated as a sub-advisor to be performed on the client’s account at their Advisor Representative’s direction. In limited instances, EPS will work directly with the client. In addition to the EPS sub-advisory services offered in the Programs, EPS also offers advisory service tools, whereby EPS provides only administrative and technology services and investment research and due diligence. The selection of services offered by EPS includes, but is not limited to: Investment policy planning assistance. Identification of appropriate managers and investment vehicles suitable for the client’s goals. • Assessment assistance of the client’s investment needs and objectives. • • Assistance in the development of an asset allocation strategy designed to meet the client’s objectives. • Recommendations on appropriate style allocations. • • Evaluation of asset managers and investment vehicles meeting style and allocation criteria. • Engagement of selected asset managers and investment vehicles on behalf of the client. • Ongoing monitoring of individual asset managers’ performance and management for “approved” investment strategies. • Automated tools that assist in the review of client accounts to ensure adherence to policy guidelines and asset allocation. • Recommendations for account rebalancing, if necessary. • Online reporting of the client account’s performance and progress. • Fully integrated back-office support systems to advisors, including interfacing with the client’s custodian, trade order placement, confirmation and statement generation. • Access to third-party platforms and strategies through the eps platform. Clients should refer to their TPM’s current ADV 2A and Program Agreement for complete details and the Programs available for selection. The Programs Integrated or the Adviser will work with clients and EPS to select a MAS Program suitable for their investment 11  needs. Clients will review the referred Manager’s disclosure brochures and choose from available options. A summary of several TPM Program choices follows: Separately Managed Accounts (“SMA”) Program - The SMA Program is an actively managed or index-ed investment portfolio managed by a roster of independent asset managers (each a “sub-manager”) with various disciplines who have been granted discretion. A separately managed account is a portfolio of individually owned securities that can be tailored to fit the client’s investing preferences. EPS will assist Integrated with identifying individual asset managers and investment vehicles corresponding to the proposed asset classes and styles, or Integrated may independently identify asset managers. EPS retains the sub-managers for portfolio management services connected with the SMA program through separate agreements between EPS and the sub-manager on appropriate terms and conditions. For many sub-managers, EPS has entered into a licensing agreement with the sub-manager, whereby EPS performs overlay management, administrative and/or trade order placement duties pursuant to the investment directions of the sub-manager. The sub-manager acts as a model provider in such a situation. Clients may also select individual Funds through the SMA program. Third-Party Fund Strategists Program - This Program includes asset allocation strategies of various mutual fund and ETF asset managers. Each portfolio may consist solely of mutual funds or ETFs or combine both types of funds to pursue different investment strategies and asset-class exposures. Pursuant to a licensing agreement with the Model Provider, Envestnet provides overlay management of the portfolios and performs administrative and trade order placement duties according to the direction of the model provider. UMA Program (“UMA”) - For clients participating in the UMA Program, a single portfolio that accesses multiple asset managers and Funds is recommended, representing various asset classes customized by the client’s Advisor Representative. Utilizing the Envestnet tools, the asset allocation models for a particular client are selected, or Envestnet’s proposed asset allocations for types of investors fitting the client’s profile and investment goals are chosen. Portfolios are further customized by selecting the specific underlying investment strategies or Funds in the portfolio to meet the client’s needs. Once portfolio content is established, Envestnet provides overlay management services for UMA accounts and places trade orders based on the investment strategies contained in the UMA portfolio. MMA portfolios may also be offered, created and managed by third- party asset managers that access multiple asset managers and Funds representing various asset classes within the UMA program. A UMA portfolio sub-manager may also be selected within the UMA program, which customizes and manages the single portfolio by choosing the specific underlying investment strategies or Funds in the portfolio. (See Strategist UMA below.) Client-Directed UMA - This is a version of the UMA whereby the Advisor does not exercise investment discretion in selecting the asset allocation or the specific, underlying investment vehicles and strategies used in each sleeve of the UMA portfolio (“client-Directed UMA”). In this Program, the client is provided with recommendations regarding the appropriate asset allocation and the underlying investment vehicles or investment strategies to meet their objectives. Still, the client directs the investments and changes made to the UMA portfolio, with ultimate responsibility for the selection of the appropriate asset allocation and the underlying investment vehicles or investment strategies. As described previously, EPS provides overlay management services for UMA accounts and places trade orders based on the directions of the investment strategies contained in the UMA portfolio. PMC Multi-Manager Account Program (“PMC MMA”) - Includes portfolios created and managed by PMC that access multiple asset managers and Funds representing various asset classes. PMC allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. PMC includes Funds in the PMC MMA to complete the asset class exposure of the asset managers utilized. Because EPS does not have to share management fees with Fund families but does share management fees with third-party Model Providers, EPS has an economic incentive to choose Funds rather than third-party strategist portfolios within the PMC MMA. Strategist UMA Program (“Strategist UMA”) - Portfolios created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategist allocates the portfolios across investment asset classes, using complementary asset managers to create a blend that fits the target investment profile and risk tolerance. 12  Manager OC Services Program - MMA portfolios are created and managed by third-party investment strategists that access multiple asset managers and Funds representing various asset classes. The third-party investment strategists allocate the portfolios across investment asset classes and complementary asset managers to create a blend that fits the target investment profile and risk tolerance, while the Advisor has full discretion over investments. The third-party investment strategists include Funds in the Manager OC Services to complete the asset class exposure of the asset managers utilized. Other customized portfolio management programs are also available. In selecting a referred third-party manager, the client is responsible for understanding the TPM’s Program Agreement, Programs, and fee agreement they are executing with the referred manager. Clients should consult the referred manager's prospectus and related disclosure documentation for precise details concerning the fees they may pay, important manager disclosures, account discretion and custody practices, account investments and risks and Program investment limitations. In short, clients should review all applicable disclosure brochures before participating in any TPM Program. Integrated and/or Adviser receives compensation from third-party advisers when we recommend you use their services. These compensation arrangements present a conflict of interest because we have a financial incentive to recommend the services of the TPM. Clients are not obligated to use the services of any referred advisor we recommend, contractually or otherwise. We do not have any other business relationships with the recommended TPMs. (See “Conflicts of Interest” at the end of this section for other important information.) Integrated and/or Adviser can allocate assets among private funds, including funds of funds, managed by third parties. With respect to funds of funds, Integrated recommends funds on an alternative investment platform that manages feeder funds that invest in private offerings managed by third parties. All relevant information, terms and conditions relative to private funds, including the investment objectives and strategies, minimum investments, liquidity terms, qualification requirements, suitability, fund expenses, risk factors, and potential conflicts of interest, are set forth in the offering documents that each investor is required to receive and/or execute prior to being accepted as an investor in a fund. Neither Integrated does not invest clients in private funds without prior approval from the client, and the client must complete the subscription documents. Financial Planning ZWAG LLC through Integrated will typically provide a variety of financial planning services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: investment planning, retirement planning, estate planning and charitable planning, education planning, and business planning. The plan developed for financial consultation rendered to the client will usually include general recommendations for a course of activity or specific actions to be taken by the client(s). For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. ZWAG LLC may also refer clients to an accountant, attorney or other specialist. For planning engagements, Adviser will provide a summary of the client’s financial situation, observations, and recommendations. For consulting engagements, the Adviser may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. There is an inherent conflict of interest for ZWAG LLC whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services. ZWAG LLC minimizes this potential conflict of interest by not accepting any commissions, referral fees, or other 13  compensation for referrals to, or services provided, by outside professionals. Financial planning clients who choose to use ZWAG LLC for investment management services, any uncollected financial planning fees are waived when investment management services begin, and financial planning services are offered to investment management clients at no additional cost for the financial planning services. Neither Adviser nor Integrated make any representation that these products and services are offered at the lowest available cost, and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Adviser or use the services of ZWAG LLC. Hourly & Fixed Fee Consulting Services Adviser provides consulting hourly and fixed-fee consulting services, on investment and non-investment-related matters, on a separate fee basis, available for clients who need advice on a limited scope of work. After completion of a Consulting Services Agreement, the services generally include receiving a written financial plan consistent with the client's financial status, investment objectives, and tax status, which may include any combination of the following: lifestyle objectives, retirement or significant purchase planning, life and disability insurance requirements, long-term care needs, and estate planning issues. If requested by the client, Adviser may recommend the services of other professionals for implementation purposes. As with all recommendations, the client is not obligated to engage any recommended professional's services or act upon any recommendation provided. The client retains absolute discretion over all such implementation decisions and is free to accept or reject Integrated's recommendation regarding this or any other Integrated advisory services in which they engage. This type of service also does not constitute an agreement for client management or advisory services. The client is responsible for determining whether to implement any recommendations by the Adviser Representative and placing any resulting transactions. After engagement completion, Integrated and the Adviser Representative do not provide ongoing consulting or management services or have discretionary authority for the client's assets. Clients should consult their Consulting Services Agreement for complete details. (See “Conflicts of Interest” at the end of this section for other important information.) Educational Seminars & Workshops Services Adviser provides complimentary investment educational seminars and workshops services on various investment topics "as-announced" for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content varies depending on attendee needs and does not involve selling investment products. The information presented will not be based on any individual's needs. Adviser Representatives will not provide personalized investment advice to attendees during such events. Integrated and Adviser provide investment advice only if engaged independently and where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes only and do not deliver specific accounting, investment, legal, tax, or other professional advice. Attendees have no obligation to schedule a consultation, purchase services from Integrated or affiliates, or become clients. Integrated observes the Adviser’s privacy practices with respect to the sharing of seminar and workshop services information. (See Item 10: Other Financial Industry Activities & Affiliations.) Conflicts of Interest Please note that Integrated and/or Adviser has an inherent conflict of interest in offering and providing the above advisory services, giving the Adviser an incentive to recommend clients use advisory or third-party referred manager services based on the compensation received by the Adviser rather than client needs. Integrated and Adviser mitigates this conflict by placing client interests first, always. While clients can purchase recommended investment products through Integrated or other brokers or agents not affiliated with the Firm, they are not obligated to act upon the Adviser's recommendations. Further, if they act on any recommendations received, they are under no obligation to affect the transaction through Integrated, its Adviser Representatives, Associates, or any other third 14  party. Clients may act on the firm's recommendations by placing securities transactions with any brokerage firm or third party. Clients are not obligated to act upon any recommendations or purchase any additional products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through Integrated or any recommended third party. The client may act on recommendations by placing their business and securities transactions with any brokerage firm or third party. Integrated does not represent that the products or services offered are at the lowest available cost - clients may be able to obtain the same or similar products or services at a lower price from other providers. Additional details of how Integrated mitigates conflicts of interest can be found in Integrated’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Types of Investments Adviser will generally provide investment and portfolio asset allocation advice and management on the following investment types: • Cash, cash equivalents, and money market funds • Equities (stocks). • Corporate debt securities. • Digital Assets / Bitcoin • Exchange-traded funds (“ETFs”). • Investment company securities - including mutual fund shares (no-load/ low-load), variable life insurance, and variable annuities. • Options contracts (including limited use for hedging or income strategies, where appropriate). • Warrants. • U.S. government securities. Although Adviser provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, tailored needs, individual goals, and objectives. Integrated and Adviser avoid market timing but will increase cash holdings when necessary. While we primarily advise on the items listed above, we may offer advice on various investments based on your stated goals and objectives. We may also advise on any investment held in your portfolio at the inception of our advisory relationship. Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives. We will also use other securities to help diversify a portfolio when appropriate. As a fiduciary, an investment adviser is expected to provide investment advice in the client's best interest. When recommending investments in mutual funds, it is Integrated's and Advisers’ policy to consider all available share classes and to select the most appropriate share classes based on various factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges, availability, and other factors. Institutional share class mutual funds typically cost less than other share classes. Generally, they do not have an associated 12b-1 fee, leading to a lower overall expense ratio than other class shares of the same mutual fund. Therefore, in most cases, it will be in the client's best interest to recommend or purchase share classes with the lowest cost, typically, an institutional share class. Client Tailored Services Integrated offers all its clients the same suite of tailored services as described herein. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at the Adviser's 15  discretion, as detailed herein and defined in each client's written Agreement. Client-Imposed Restrictions Investment management and supervisory services clients who engage Integrated on a discretionary basis may, at any time, impose restrictions, in writing, on the Adviser’s discretionary authority. Clients may restrict investing in particular securities or security types according to their preferences, values, or beliefs. They may also amend/change such limitations by providing written instructions. Reasonable efforts are used to comply with client investment guidelines by standard industry practices. Upon receiving a client's written restrictions, Adviser will discuss the restriction request's feasibility to ensure expectations are met and confirm the client's acknowledgment and understanding of the imposed restriction's possible outcomes. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similarly managed account without restrictions. Client-imposed account restrictions and variations could result in positive or negative performance differences for their portfolio compared to the investment program's performance composite. Investment structures recommended can also prevent controlling a client's specific outcome. Neither Integrated nor Adviser is obligated regardless of the advisory service provided to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. If client- imposed restrictions prevent a client's account's proper servicing or require substantial deviations from recommendations, Integrated and/or Adviser reserves the right to end the client relationship. Third-party management services clients may impose restrictions on their TPM Program Accounts according to the referred manager's Program Agreement. WRAP Program As part of its services, Integrated and certain of its independent investment professional DBA entities offering their advisory services through Integrated will provide investment and portfolio management services via a Wrap Fee Program. A Wrap Fee Program, a transaction fee rebate program, differs from a regular advisory services account in that clients receive both investment advisory management services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee” or "Wrap Fee" - a single fee that covers both advisory services and certain transaction costs). Assets in the Wrap Fee Program are regularly monitored, and investment strategy purchase and sale transactions are based on the client’s specific needs and investment goals. Before participating in the Wrap Fee Program, clients will be required to enter into a separate written Wrap Fee Program Agreement with Integrated that sets forth the terms and conditions of the engagement, describes the scope of services to be provided, and the fees to be paid. The annual wrap fee for participation depends upon the market value of the client assets under our management. Clients will invest by establishing one or more accounts (the "managed accounts" or "accounts"), each of which is reviewed for qualification and suitability. Appropriateness will be determined based solely on the Program's cost-effectiveness to the client. The SEC rules require that a Wrap Fee Program brochure be given to the client before entering into this program contract. Please see our ADV Part 2A Appendix 1 Brochure for more information on this service and each independent advisory entity’s Form ADV Part 2A - Appendix I Wrap Fee Brochure, as applicable, for additional important information about the Wrap Fee Program services they offer, including any associated fees and charges. ZWAG does not use Third-party management services, wrap fee programs, or Managed Account Solutions. Assignment of Investment Management Agreements 16  Our investment advisory agreements generally may not be assigned without the prior written consent of the client, as required under applicable federal and/or state securities laws. An “assignment” may include a direct or indirect transfer of our advisory contract, including a change in control of the Firm. In the event of an assignment, clients will be notified in advance and asked to provide consent to the assignment of their advisory agreement. If client consent is not obtained, the advisory agreement would terminate in accordance with its terms. In certain circumstances, where permitted by applicable law, client consent to an assignment may be obtained through negative consent, meaning the client’s consent is presumed if the client does not object within a specified time period after receiving written notice. Clients will always be informed of their right to object or terminate the advisory relationship. Assets Under Management As of December 31, 2025, Integrated Advisors Network collectively managed approximately $5,522,561,843. The following represents client assets under management by account type: Assets Under Management Account Type Discretionary Non-Discretionary Total $5,286,824,594 $235,737,249 $5,522,561,843 Item 5 – Fees and Compensation Under the Investment Advisers Act of 1940's "Brochure Rule," investment advisers must provide a written disclosure statement to their clients. A copy of ZWAG’s Form ADV Part 2A Brochure, the applicable Advisor Representative’s Part 2B Brochure Supplement, and Form CRS (ADV Part 3) will be provided to clients before or during client Agreement execution. Unless clients receive these important disclosure documents at least 48 hours before signing their Investment Management Agreement, they may terminate their Agreement with Integrated within five (5) business days of Agreement execution without incurring any advisory fees. (Note: Advisers offering impersonal investment advice paid less than $500 per year do not have to adhere to the client Brochure Rule.) Regardless of fee negotiation availability, a client will not be required to pre-pay an Integrated advisory fee more than six months in advance in excess of $1,200. Investment Management Investment Management Services Fee Calculations Advisory Fees charged are based on a percentage of the client’s assets under management and are established on a client-by-client basis. The specific ways ZWAG LLC charges its fees are established in each client’s written Investment Advisory Contract. Generally, clients will be invoiced in arrears at the end of each calendar quarter based upon the average daily value of their assets under management (market value based on independent third- party sources, or fair market value in the absence of market value) during the calendar quarter. Investment Management service fees are based on assets under management (“AUM”) and will be calculated at the annualized rates reflected below and charged quarterly. The standard Investment Management services annual fee will be charged as a percentage of assets under management, according to the tiered schedule below: 17  $ - $ 1,000,000.01 $ 2,500,000.01 $ 5,000,000.01 $ 7,500,000.01 $ 10,000,000.01 to to to to to and $ 1,000,000.00 $ 2,500,000.00 $ 5,000,000.00 $ 7,500,000.00 $ 10,000,000.00 over 1.00% 0.75% 0.50% 0.25% 0.10% 0.00% The fee schedule operates as a tiered schedule, meaning that fees are charged at the level indicated for the assets in each range. For example, a client who enlists ZWAG LLC to manage a portfolio of $2,600,000 would pay us 1% of the first $1 million, 0.75% of the next $1.5 million and 0.50% on the remaining $100,000. Our standard minimum quarterly fee is $1,000. Investment Management service fees (including the minimum quarterly fee) are negotiable. New accounts are charged a prorated fee for the remainder of the quarter in which investment operations begin as determined by the date of the first trade in client accounts under management. In most circumstances, this will occur after the date the IPS is signed and the date that client accounts are fully or partially funded. Investment Management Services Fee Billing ZWAG LLC’s clients agree to pay an asset-based fee (advisory fee) calculated according to the tiered Fee Schedule above, calculated on the average daily balance of assets under management during the quarterly billing period. ZWAG LLC will request authority from the client to receive its quarterly payment advisory fees directly from the client's account held at their independent qualified Custodian. The client’s independent qualified Custodian will maintain actual custody of their assets. While ZWAG LLC requires its clients to authorize it to deduct fees from their account(s) held by their Custodian, clients must provide ZWAG LLC with written limited authorization to allow the Investment Adviser to withdraw management fees from their account. Clients may elect to have their quarterly fees charged to either one account or split between their other accounts. Under rare circumstances, clients may be given the option to pay fees directly to the Adviser via check or by electronic funds transfer. Advisors’ fees are due and will be debited (if not paid by check), from the client’s Custodial account(s), in the first month following the end of the quarter (January, April, July, October). Clients will receive Custodial statements showing ZWAG LLC’s advisory fees being debited from their account. To bill an account, ZWAG LLC will: • Obtain written authorization from the client, permitting ZWAG LLC to be paid directly from the client’s account, held by their Custodian. • • Send the client an invoice specifying and itemizing any fees assessed, while concurrently sending a copy of the client’s invoice details to their Custodian. (Note: For many Custodians, the invoice information will be presented in the form of a data sheet reflecting client invoice details, an uploaded to deduct fees, not a copy of the actual invoice the client received.) Instruct the Custodian to send the client statements at least quarterly, to the email or postal mailing address the client provided to the Custodian, showing all disbursements for the account, including the amounts of any assessed Advisory fees. Payment for management fees will be made by the qualified custodian holding the client’s funds and securities. Integrated will calculate the advisory fees due based on the client’s Agreement. The account custodian does not verify the accuracy of Integrated's advisory fee calculation. Upon receiving Integrated’s instructions, the qualified custodian will automatically deduct and pay Integrated from the client’s account the fee amount due at the quarter’s end, regardless of the portfolio’s market performance during the preceding quarter. (Please note that when 18  authorized by the client to debit advisory fees from client accounts, Integrated is deemed to have custody of client assets to the extent the adviser is permitted to instruct custodians to deduct advisory fees due.) Integrated will direct the client’s custodian to deliver to the client at their account address of record - or another authorized address, as otherwise designated by the client in writing - a statement reflecting the fee amounts paid to Integrated for the quarter in question. Clients who do not receive statements directly from their custodian should promptly contact their custodian and Integrated to advise them of the missing items. Integrated urges clients to review any custodial account statements received upon receipt and compare them against the appropriate benchmark for their portfolio and any periodic portfolio report or data they may receive from us to ensure the accuracy of account transactions. Information from us may vary based on accounting procedures, reporting dates, or valuation methodologies. Investment Management Account Terminations A client Investment Advisory Agreement (“Advisory Agreement”) may be cancelled at any time, by either party, for any reason upon receipt of 10 days written notice. Upon termination of any account at any time after the required 10-day notice, a pro-rated invoice for services provided through termination date will be sent to the client. The client has the right to terminate their Advisory Agreement without penalty within five (5) business days after executing their Advisory Agreement. Effective with the date of termination, ZWAG LLC shall refrain, without liability or obligation, from taking any further action in a client’s account(s). From the date of termination, ZWAG LLC will cease to be entitled to receive fees. Cancellation will be subject to any changes related to the settlement of transactions in progress. Any unearned pre-paid fees will be refunded to the client on a pro-rata basis, based on the date of termination. Employee Benefit Plan Services Fees Note: Employee Benefit Retirement Plan Services annual fees are charged as a percentage of assets within the plan, according to the above-quoted fees for Investment Management Services fees, for ongoing management of assets. For a review of plans that does not include management of assets, a negotiable fixed fee will be charged. Employee Benefit Plan Services Fee Billing Employee Benefit Plan Services Billing follows the same procedures as “Investment Management Account Billing,” above for management of assets. Please refer to that section, for billing specifics. For an Investment Review of an Employee Benefit Plan, a negotiable fixed fee applies. Investment Review Fees Investment Reviews will generally be offered on a fixed fee basis. Fees are negotiable and must be paid by electronic funds transfer or by check at the end of the service; cash is not accepted. Investment Review Fee Billing Clients will receive an invoice for Investment Review fees due upon the delivery of the financial plan and a review of results with the client. Payment is due within 30 days of invoice receipt; cash is not accepted. Financial Planning Fees Financial Planning will generally be offered on a fixed fee basis. This will usually be in the form of a fixed fee for a defined engagement. Clients who wish to initiate and maintain an ongoing financial planning advisory relationship with ZWAG LLC but do not wish to engage in discretionary investment management may be given the option to engage us on an annual retainer with fees billed each calendar quarter. Fees are negotiable and must be paid by electronic funds transfer or by check; cash is not accepted. 19  Financial Planning Fee Billing If a Financial Planning fixed fee program is chosen, clients will be asked to pay an initial retainer fee equal to $1,000 or 25% of the project fee, whichever is greater. Clients will receive invoices for the remaining fee outstanding in three equal installments in 3-month intervals until all fees have been paid or until the work is completed. Once the financial plan is complete, delivered, and reviewed with the client, the client will receive an invoice for the remainder of any outstanding fees. Fees for this service may be paid by electronic funds transfer or check. Fees are negotiable and are payable within 30 days of invoice receipt. If a client chooses to engage ZWAG LLC for investment management services after initiating a financial planning engagement, ZWAG LLC may choose to waive some or all of the unpaid financial planning fees as of the onset of the Investment Management engagement. If a client prefers to engage ZWAG LLC for an ongoing financial planning relationship and pay an annual retainer, the client will be asked to pay an initial start-up fee of up to one quarter (25%) of the annualized fee at the beginning of the relationship and will be subsequently invoiced at three month intervals for one quarter (25%) of the annualized retainer. If the client chooses to discontinue services mid quarter, the client will be refunded the prorated portion of the fee that was paid but not yet earned. Fees for this service must be paid by electronic funds transfer, credit card or by check; cash is not accepted. Consultation Fees Fees for hourly consulting work will be billed at a rate of $300 per hour, unless otherwise described in the engagement letter. There is a three (3) hour minimum for consulting work. Consultation Fee Billing Clients will receive a monthly invoice for hourly consulting fees. Fees for consulting services may be paid by electronic funds transfer or check. Fees are negotiable and are payable within 30 days of invoice receipt. Integrated Fee Disclosure The clients of ZWAG LLC will not pay and will not be affected by the fees of other IARs at Integrated. The following is for disclosure purposes only. Investment Adviser Representatives of Integrated have fees that may vary from the fees disclosed herein and may be collected in arrears or in advance. These fee schedules are specific to each advisory group of Integrated. See the individual brochure for each advisory group for specific details. ZWAG LLC’s fees may be higher or lower than other advisory groups at Integrated and there is no representation that ZWAG LLC’s fees are the lowest available for similar services. Other Fees The client will likely incur additional fees from brokerages, custodians, administrators, and other service providers as appropriate. These fees are incurred as a result of managing a client account and are charged by the service provider. The amount and nature of these fees is based on the service provider’s fee schedule(s) at the provider’s sole discretion. These fees are separate and distinct from any fees charged by the Adviser. The Adviser’s services are charged on a fee only basis, and no associated persons shall earn compensation based on a securities transaction (i.e. commission) including asset-based sales charges or service fees from the sale of mutual funds. The Adviser or the sub-advisers selected by the Adviser may include mutual funds, variable annuity products, ETFs, and other managed products or partnerships in clients’ portfolios. Clients may be charged for the services by the providers/managers of these products in addition to the management fee paid to the Adviser. 20  The Adviser, from time to time, may select or recommend to separately managed clients the purchase of proprietary investment products. ZWAG does not offer nor recommend any proprietary products. To the extent the client’s separately managed portfolio includes such proprietary products the Adviser will adjust the client’s fee associated with the client’s separately managed account. The fees and expenses charged by the product providers are separate and distinct from the management fee charged by the Adviser. These fees and expenses are described in each mutual fund’s or underlying annuity fund’s prospectus or in the offering memorandums of a partnership. These fees will generally include a management fee, other fund expenses and a possible distribution fee. No-load or load waived mutual funds may be used in client portfolios so there would be no initial or deferred sales charges; however, if a fund that imposes sales charges is selected, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund or variable annuity or investment partnership directly, without the services of the Adviser. Accordingly, the client should review both the fees charged by the funds and the applicable program fee charged by the Adviser to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. If it is determined that a client portfolio shall contain corporate debt or other types of over-the-counter securities, the client may pay a mark-up or mark-down or a “spread” to the broker or dealer on the other side of the transaction that is built into the purchase price of the security. Bundled Fee Arrangement Certain IARs affiliated with Integrated may choose to bill client fees using a bundled fee arrangement. ZWAG does not use any bundled fee arrangements. This structure combines investment advisory services with certain brokerage execution, custody, reporting, and related services for a single, asset-based fee. While this arrangement is sometimes referred to as “wrap” style for convenience, it does not meet the SEC definition of a Wrap Fee Program. Under this arrangement, assets are regularly monitored, and investment decisions are based on each client’s specific needs and objectives. Clients participating in a bundled fee arrangement will enter into a written agreement that outlines the terms of engagement, the scope of services, and the applicable fees. The annual fee depends on the market value of assets under management, and suitability is determined based on the cost-effectiveness of the arrangement for the client. Because this is not a true Wrap Fee Program, clients will not receive a Wrap Fee Program Brochure unless required by regulation. For more details about the Bundled Fee payments and the services offered, please refer to this Brochure and, where applicable, the Form ADV Part 2A of each independent advisory entity for additional important information, including fees and charges. (See Item 5: Fees & Compensation for further details.) Termination of Agreements A client may terminate any of the previously mentioned agreements at any time by notifying the Adviser in writing. Clients shall be charged pro rata for services provided through to the date of termination. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser may terminate any of the previously mentioned agreements at any time by notifying the client in writing. If the client made an advance payment, Integrated will refund any unearned portion of the advance payment. The Adviser reserves the right to terminate any engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in the Adviser’s judgment, to providing proper financial advice. Conflict of Interest Between Different Fee Structures The Adviser offers several different services detailed in this brochure that compensate the Adviser differently depending on the service selected. There is a conflict of interest for the Adviser and its associated personnel to 21  recommend the services that offer a higher level of compensation to the Adviser through either higher management fees or reduced administrative expenses. The Adviser mitigates this conflict through its procedures to review client accounts relative to the client or investor’s personal financial situation to ensure the investment management service provided is appropriate. Further, the Adviser is committed to its obligation to ensure associated persons adhere to Integrated’s Code of Ethics and to ensure that the Adviser and its associated persons fulfill their fiduciary duty to clients or investors. Item 6 – Performance Fees Performance-based fees are advisory fees calculated based on a client’s account’s share of capital gains or capital appreciation, rather than on the value of assets under management. Side-by-side management refers to the practice of an investment adviser managing accounts that pay performance- based fees alongside accounts that do not pay such fees. This arrangement can create potential conflicts of interest, such as preferential treatment in trade allocation or investment opportunities. Adviser charges advisory fees based on a percentage of assets under management and does not assess performance- based fees at the firm level. However, certain IARs may offer advisory services that include performance-based fees, as disclosed in those entities’ Form ADV documents. When an Adviser Representative manages both performance-fee accounts and asset-based accounts (“side-by-side management”), potential conflicts of interest may arise, including trade allocation bias, time and attention bias, and risk-taking incentives, among others. Integrated supervises such arrangements and implements policies and procedures designed to mitigate these conflicts, including fair and equitable trade allocation, periodic reviews, and adherence to our Code of Ethics and fiduciary obligations. While certain advisory groups at Integrated charge performance fees, ZWAG does not. Item 7 – Types of Clients Description ZWAG LLC provides services primarily to high-net-worth individuals and their families, as well as to individuals and their families. ZWAG may occasionally provide services to institutions, foundations and endowments, businesses, and non-profit organizations. Client relationships vary in scope and length of service. Other advisory groups of Integrated Advisors provide services to other types of clients than is disclosed herein. Account Minimums There is no minimum account size for ZWAG LLC’s fee-only Investment Management, Financial Planning, or Investment Review services. ZWAG LLC will charge investment management clients a minimum annual fee as described in section 5 (Fees and Compensation) and as documented in the Investment Management engagement letter. Fees may be negotiated. There are no ongoing contribution requirements for client accounts. Other advisory groups of Integrated have minimums that are higher or lower or may not have any minimum size account. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Adviser provides customized investment recommendations based on each client's specific circumstances and investment objectives, as stated by the client during consultations. The information clients supply will become the basis for a strategic asset allocation plan to meet best the client's expressed personal short and long-term financial goals and objectives. Portfolio investment advice also considers client income needs, time horizon, risk tolerance, expected rates of 22  return, and asset class preferences, among other factors. Reviews may include, but are not limited to, cash flow and liquidity requirements details, tax considerations, estate planning, risk management, and other items significant to the client’s financial situation. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. In all cases, the client’s Adviser Representative will rely upon the accuracy of data furnished by the client or on their behalf without further investigation and is not required to confirm the information obtained from clients or their other professional advisors. Methods of Analysis We may use one or more of the following methods of analysis Charting Analysis - involves the gathering and processing price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data detect departures from expected performance and diversification and predict future price movements and trends. Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security, and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Cyclical Analysis - a technical analysis involving evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and fluctuate between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy, and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and, consequently, the changing value of securities that would be affected by these changing trends. ESG Criteria - an additional level of scrutiny is added to the Environmental, Social, and Governance ("ESG") criteria. Investments are typically screened using ESG criteria through reputable sources (i.e., examples can include Morningstar, Bloomberg Sustain, YCharts, FactSet, etc.). The purpose is to seek additional risk management and long-term value by investing in companies that positively impact the world and avoid companies that don't take responsibility and care of all stakeholders, including shareholders, communities, the environment, and the supply chain. ESG screening has risks, including that it may not encompass all environmental, social or governance issues and that such an approach may not lead to greater portfolio performance. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the actual value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Investment Strategies We use one or more of the following investment strategies when providing investment advice to you: Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market you are invested in, or perhaps just your particular investment, will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short term in other investments. Modern Portfolio Theory - a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk or equivalently minimize risk for a given level of expected return by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. 23  Option Writing - a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the option's expiration date. When an investor sells a call option, they must deliver a specified number of shares to the buyer if the buyer exercises the option. When an investor sells a put option, they must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the option's market price at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor's risk can be unlimited. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period, generally less than one year, to take advantage of the securities' short-term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. Many factors can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a more negligible impact over extended periods. Trading - we may use frequent trading (generally selling securities within 30 days of purchasing the same securities) as an investment strategy when managing your account(s). Frequent trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is suitable given your stated investment objectives and risk tolerance. This may include buying and selling securities frequently to capture significant market gains and avoid significant losses. Risk: When a frequent trading policy is in effect, there is a risk that investment performance within your account may be negatively affected, mainly through increased brokerage and other transactional costs and taxes. Our investment strategies and advice may vary depending on each client's financial situation. As such, we determine investments and allocations based on your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is essential that you notify us immediately with respect to any material changes to your financial circumstances, including, for example, a change in your current or expected income level, tax circumstances, or employment status. While Adviser may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. When balancing portfolios, Adviser will consider only the account’s managed assets, not other investments the client may hold elsewhere. Practices Regarding Cash Balances In Client Accounts Client cash balances are usually invested in FDIC-insured deposit accounts, money market funds, or FDIC-insured certificates of deposit. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. Integrated will manage client account cash balances based on the yield and the financial soundness of money markets and other short-term instruments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless expressly agreed otherwise in writing, tax efficiency will not be our primary consideration in managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. 24  Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately, and we will alert the account custodian of your individually selected accounting method. Please note that all decisions regarding cost basis accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement. Risks of Loss & Other Types of Risk Clients should remember that investing in securities involves a risk of loss that they should be prepared to bear, and past performance does not indicate future results. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. Integrated cannot guarantee or promise that a client's financial goals and objectives will be met. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. Neither Integrated nor the Adviser represent or guarantee that any services provided or analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. Certain assumptions may be made regarding interest and inflation rates, past trends, and the performance of the market and economy. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is in no way an indication of future results, and the investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks and will not always be profitable, and no investment strategy can guarantee a profit or protect against loss during declining values. Further, the outcome(s) described, and any strategy or investments discussed may not suit all investors. Neither Integrated nor the Adviser are engaged in law and do not provide legal or tax advice, accounting, or bookkeeping services. When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of potential losses. There can be no assurance that advisory services will result in any particular result, tax, or legal consequence. The following risks, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services: (Note: Items are presented alphabetically for ease of reading, not in order of importance.) Bank Obligations - including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are affected by interest rates and may be adversely affected by downturns in the US and foreign economies or banking regulation changes. Bonds - corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer, the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" before maturity. When a bond is called, it may be impossible to replace it with a bond of equal character paying the same rate of return. Bond Funds - have higher risks than money market funds, primarily because they typically pursue strategies to produce higher yields. Unlike money market funds, the SEC's rules do not restrict bond funds to high-quality or short-term investments. Because there are many different bonds, these funds can vary 25  dramatically in their risks and rewards. Some risks associated with bond funds include credit, interest rate, and prepayment risks. Business Risk - is the risks associated with a specific industry or company. Certificates of Deposit Risk - certificates of deposit (“CDs”) are generally a safe type of investment since they are insured by the Federal Deposit Insurance Company (“FDIC”) up to a certain amount. However, because the returns are generally low, there is a risk that inflation outpaces the CD’s return. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In addition to trading risk, the FDIC does not cover the price when CDs are purchased at a premium. Competition Risk - the securities industry and advisers' varied strategies and techniques are incredibly competitive. Advisory firms, including many larger securities and investment banking firms, may have more significant financial resources and research staff than this firm. Conflicts of Interest - advisers face inherent conflicts when administering client portfolios and financial reporting. They mitigate these conflicts through comprehensive written supervisory compliance policies and procedures and COE, which provides that the client's interest is always held above that of Integrated and its Associates. Corporate Bond Risk - corporate bonds are debt securities to borrow money. Issuers pay investors periodic interest and repay the amount borrowed periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest but are priced at a discount from their face values, and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond's maturity, the higher its interest rate risk. Credit Risk - credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond-issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. Currency/Exchange Risk - overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. Diversification Risk - a portfolio may not be widely diversified among sectors, industries, geographic areas, or security types or may not necessarily be diversified among many issuers. These portfolios might be subject to more rapid change in value than would be the case if the investment vehicles were required to maintain a broad diversification among companies or industry groups. Equity Investment Risk - generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the stock's value increases. An inherent risk is involved when purchasing a stock that may decrease value; the investment may incur a loss. Financial Risk - is the possibility that shareholders will lose money when they invest in a company with debt if its cash flow proves inadequate to meet its financial obligations. When a company uses debt financing, its creditors will be repaid before its shareholders should the company become insolvent. Financial risk also refers to the possibility of a corporation or government defaulting on its bonds, which would cause those bondholders to lose money. Fixed Income Call Option Risk - including agency, corporate and municipal bonds and all mortgage- backed securities, contain a provision that allows the issuer to "call" all or part of the issue before the bond's maturity date. The issuer usually retains this right to refinance the bond in the future if market interest rates decline below the coupon rate. There are disadvantages to the call provision: the cash flow pattern of a callable bond is not known with certainty because the issuer will call the bonds when interest rates have dropped. There is exposure to reinvestment rate risk - investors will have to reinvest the proceeds received when the bond is called at lower interest rates. The capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. 26  Foreign/Non-U.S. Investments - from time to time, advisers may invest and trade a portion of client portfolios in non-U.S. securities and other assets (through ADRs and otherwise), which will give rise to risks relating to political, social, and economic developments abroad, as well as risks resulting from the differences between the regulations to which US and foreign issuers and markets are subject. Such risks may include political or social instability, the seizure by foreign governments of company assets, acts of war or terrorism, withholding taxes on dividends and interest, high or confiscatory tax levels, limitations on the use or transfer of portfolio assets, enforcing legal rights in some foreign countries is difficult, costly, and slow, and there are sometimes unique problems enforcing claims against foreign governments, and foreign securities and other assets often trade in currencies other than the US dollar. Advisers may directly hold foreign currencies and purchase and sell foreign currencies through forward exchange contracts. Changes in currency exchange rates will affect an investment's net asset value, the value of dividends and interest earned, and gains and losses realized on the sale of investments. An increase in the strength of the US dollar relative to these other currencies may cause the value of an investment to decline. Some foreign currencies are particularly volatile. Foreign governments may intervene in the currency markets, causing a decline in the value or liquidity of an investor's foreign currency holdings. If an investor enters forward foreign currency exchange contracts for hedging purposes, it may lose the benefits of advantageous changes in exchange rates. On the other hand, if an investor enters forward contracts to increase return, it may sustain losses. Non-U.S. securities, commodities, and other markets may be less liquid, more volatile, and less closely supervised by the government than in the United States. Foreign countries often lack uniform accounting, auditing, and financial reporting standards, and there may be less public information about issuers' operations in such markets. Hedging Transaction Risk - investments in financial instruments such as forward contracts, options, commodities and interest rate swaps, caps and floors, other derivatives, and other investment techniques are commonly utilized by investment funds to hedge against fluctuations in the relative values of their portfolio positions because of changes in currency exchange rates, interest rates, and the equity markets or sectors thereof. Any hedging against a decline in portfolio positions' value does not eliminate fluctuations in portfolio positions' values or prevent losses if such positions decline but establishes other positions designed to gain from those same developments, thus moderating the portfolio positions' decline value. Such hedging transactions also limit the opportunity for gain if the portfolio positions' value increases. Horizon & Longevity Risk - The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments you were expecting to hold for the long term. You may lose money if you must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. Inflation & Interest Rate Risk - Security prices and portfolio returns will likely vary in response to inflation and interest rate changes. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates which may cause the value of many fixed-income investments to decline. Investment Activities - investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors that are neither within the control of nor predictable by Integrated. As further detailed within this section, decisions made for client accounts are subject to various market, currency, competitive, economic, political, technological, and business risks, and a wide range of other conditions - including pandemics or acts of terrorism or war, which may affect investments in general or specific industries or companies. The securities markets may be volatile, and market conditions may move unpredictably or behave outside the range of expectations, adversely affecting a client's ability to realize profits or resulting in material loss. Client and Integrated investment decisions will not always be profitable. Lack of Registration Risk - funds, private placements, or LP interests have neither been registered under the Securities Act, securities, or "blue sky" laws of any state and, therefore, are subject to transfer restrictions and legislative changes or court rulings may impact the value of investments or the securities' 27  claim on the issuer's assets and finances. Leverage Risk - leverage requires the pledging of assets as collateral, and margin calls or changes in margin requirements could result in the need to pledge additional collateral or liquidate account holdings, requiring the account to close positions at substantial losses not otherwise be realized. There can be an increase in the risk of loss and volatility for accounts that use leverage by engaging in short sales, entering swaps and other derivatives contracts, or different leveraging strategies. Limited Partnerships Risk - a limited partnership is a financial affiliation with at least one general partner and several limited partners. The partnership invests in a venture, such as real estate development or oil exploration, for financial gain. The general partner runs the business and has management authority and unlimited liability. And, in the event of bankruptcy, it is responsible for all debts not paid or discharged. The limited partners have no management authority, and their liability is limited to the amount of their capital commitment. Profits are divided between general and limited partners according to an arrangement formed at the creation of the partnership. The range of risks depends on the nature of the partnership and is disclosed in the offering documents if privately placed. Publicly traded limited partnerships have similar risk attributes to equities. However, like privately placed limited partnerships, their tax treatment differs from the equities' tax regime. Investors should consult with their tax adviser regarding their tax treatment. Liquidity Risk - the risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or selling the investment may not be possible. Long-Term Trading Risk - long-term trading is designed to capture return and risk market rates. Due to its nature, the long-term investment strategy can expose clients to risks that typically surface at multiple intervals when they own the investments. These risks include but are not limited to inflation (purchasing power) risk, interest-rate risk, economic risk, market risk, and political/regulatory risk. Managed Futures Funds Risk - a managed futures mutual fund invests in other funds. The underlying funds will typically employ various actively managed futures strategies that will trade various derivative instruments, including (i) options, (ii) futures, (iii) forwards, or (iv) spot contracts, each of which may be tied to (i) commodities, (ii) financial indices and instruments, (iii) foreign currencies, or (iv) equity indices. Managed futures strategies involve substantial risks that differ from traditional mutual funds. Each underlying fund is subject to specific risks, depending on the fund's nature. These risks include liquidity, sector, foreign currency, fixed-income securities, commodities, and other derivatives. Investing in underlying funds could affect the timing, amount, and character of distributions to you and, therefore, increase the amount of taxes you pay. Each underlying fund is subject to investment advisory and other expenses, including potential performance fees. An investor's cost of investing in a managed futures fund will be higher than investing directly in underlying funds and may be higher than other mutual funds that invest directly in stocks and bonds. Investors will indirectly bear fees and expenses charged by the underlying funds and the fund's direct fees and expenses. Each underlying fund will operate independently and pay management and performance-based fees to each manager. The underlying funds will pay various management fees from assets and performance fees of each underlying fund's returns. There could be periods when fees are paid to one or more underlying fund managers even though the fund has lost the period. Margin Risk - securities purchased on margin in a client's account are a firm's collateral for a client's loan. If the account securities decline in value, so does the value of the collateral supporting loan, and, as a result, the firm can act by issuing a margin call or selling securities or other assets in any of the accounts the investor may hold with the member, to maintain the required equity in the account. Understanding the risks involved in trading securities on margin is essential. These risks include but are not limited to losing more funds than deposited in the margin account, the firm forcing the sale of securities or other assets in the account(s) or selling securities or other assets without contacting the investor, or the investor not being entitled to choose which securities or other assets in their account(s) can be liquidated or sold to meet a margin call. Further, a firm can increase its "house" maintenance margin requirements without providing 28  an advance written notice, without entitlement to an extension of time on the margin call. Market Risk - market risk involves the possibility that an investment's current market value will fall because of a general market decline, reducing the investment value regardless of the issuer's operational success or financial condition. The price of a security, option, bond, or mutual fund can drop due to tangible and intangible events and situations. External factors cause this risk, independent of a security's underlying circumstances. The adviser cannot guarantee that it will accurately predict market, price, or interest rate movements or risks. Material Non-Public Information Risk - because of their responsibilities in connection with other adviser activities, individual advisory Associates may occasionally acquire confidential or material non-public information or be restricted from initiating transactions in specific securities. The adviser will not be free to act upon any such information. Due to these restrictions, the Adviser may be unable to initiate a transaction that it otherwise might have started and may not be able to sell an investment it otherwise might have sold. Money Market Funds - a money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, the share price is not guaranteed to stay at $1/share. You can lose some or all of your principal if the share price decreases. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than expected, you may need more cash. A final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over long periods, inflation can eat away at your returns. Municipal Securities Risks - municipal securities, while generally thought of as safe, can have significant risks associated with them, including, but not limited to: the creditworthiness of the governmental entity that issues the bond, the stability of the revenue stream that is used to pay the interest to the bondholders, when the bond is due to mature, and, whether or not the bond can be "called" before maturity. When a bond is called, it may not be possible to replace it with one of equal character paying the same amount of interest or yield to maturity. Municipal securities are backed by either the full faith and credit of the issuer or by revenue generated by a specific project - like a toll road or parking garage for which the securities were issued. The latter type of securities could quickly lose value or become virtually worthless if the expected project revenue does not meet expectations. Mutual Funds & Exchange Traded Funds - mutual funds and exchange-traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small-cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock, and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no-load" and charge no fee to buy into, or sell out of, the fund, other mutual funds do charge such fees, which can also reduce returns. Mutual funds can also be "closed-end" or "open-end." So-called "open-end" mutual funds continue to allow in new investors indefinitely, whereas "closed-end" funds have a fixed number of shares to sell, limiting their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment 29  adviser may not be able to cause the ETF's performance to match that of its Underlying Index or another benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks daily, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index but are expected to yield similar performance. Non-U.S.Investment Risk - investment in non-U.S. issuers or securities principally traded outside the United States may involve certain unique risks due to economic, political, and legal developments, including but not limited to favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, risks relating to political, social and economic developments abroad, as well as risks resulting from the differences between the regulations to which U.S. and foreign issuers and markets are subject and the imposition of withholding taxes on dividend or interest payments. Options Contracts Risks - options are complex securities that involve risks and are not suitable for everyone. Options trading can be speculative and carry a substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. Option buyers and sellers should be aware of the option trading risks associated with their investment(s). Political & Legislative Risk - companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the U.S. or those conducting a substantial amount of their business outside the U.S. Portfolio Turnover Risk - an account's investment strategy may require active portfolio trading. As a result, turnover and brokerage commission expenses may significantly exceed those of other investment entities of comparable size. Private Investment Risk - investments in private funds, including debt or equity investments in operating and holding companies, investment funds, joint ventures, royalty streams, commodities, physical assets, and other similar types of investments, are highly illiquid and long-term. A portfolio's ability to transfer or dispose of private investments is expected to be highly restricted. The ability to withdraw funds from LP interests is usually restricted following the withdrawal provisions contained in an Offering Memorandum. In addition, substantial withdrawals by investors within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, possibly reducing the value of the fund's assets or disrupting the fund's investment strategy. Private Placement Risks- a private placement (non-public offering) is an illiquid security sold to qualified investors and not publicly traded or registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to this illiquidity. Most securities acquired in a private placement will be restricted and must be held for an extended time and, therefore, cannot be easily sold. The range of risks depends on the nature of the partnership and is disclosed in the offering documents. Public Information Accuracy Risk - an adviser can select investments, in part, based on information and data filed by issuers with various government regulators or other sources. Even if they evaluate all such information and data or seek independent corroboration when it's considered appropriate and reasonably 30  available, the Adviser cannot confirm its completeness, genuineness, or accuracy. In some cases, complete and accurate information is not available. Real Estate Risks - real estate is increasingly being used as part of a long-term core strategy due to increased market efficiency and increasing concerns about the future long-term variability of stock and bond returns. Real estate is known for its ability to serve as a portfolio diversifier and inflation hedge. However, the asset class still bears a considerable amount of market risk. Real estate has shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In addition to employment and demographic changes, real estate is also influenced by changes in interest rates and the credit markets, which affect the demand and supply of capital and, thus, real estate values. Along with changes in market fundamentals, investors wishing to add real estate as part of their core investment portfolios need to look for property concentrations by area or property type. Because property returns are directly affected by local market basics, real estate portfolios that are too heavily concentrated in one area or property type can lose their risk mitigation attributes and bear additional risk by being too influenced by local or sector market changes. Real Estate Investment Trusts Risk - a real estate investment trust ("REIT") is a corporate entity that invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong, or the REIT must either dip into reserves, borrow to pay dividends or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, leading to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. REITs have specific risks, including valuation due to cash flows, dividends paid in stock rather than cash, and debt payment resulting in the dilution of shares. Recommendation of Particular Types of Securities Risk - we may advise on other investments as appropriate for each client’s customized needs and risk tolerance. Each security type has its unique set of risks, and it would be impossible to list all the specific risks of every investment type here. Even within the same type of investment, risks can vary widely. However, the higher the anticipated investment return, the greater the risk of associated loss. Reinvestment Risk is the risk that future investment proceeds must be reinvested at a potentially lower return rate. Reinvestment Risk primarily relates to fixed-income securities. Reliance on Management & Key Personnel Risk - occurs when investors have no right or power to participate in a firm's management. Investors must be willing to entrust all management aspects to a company's management and key personnel. The investment performance of individual portfolios depends mainly on the skill of key personnel of a firm and including its sub-advisors, as applicable. If key staff were to leave the firm, the firm might not find equally desirable replacements, and the accounts' performance could be adversely affected. Securities Futures Contracts - (on tangibles and intangibles) a futures contract is a standardized, transferable, exchange-traded contract requiring delivery of a commodity, bond, currency, or stock index specified price on a selected specified price future date. Unlike options the holder may or may not choose to exercise, futures contracts must purchase the underlying asset at a set future date. The holder of a futures contract must have sold it by that date or be prepared to pay for and take delivery of the underlying asset. Material risks can include but are not limited to futures contracts that have a margin requirement that must be settled daily, there is a risk that the market for a particular futures contract may become illiquid, and the market price for a particular commodity or underlying asset might move against the investor requiring that the investor sell futures contracts at a loss. 31  Short-Sales Risk - short sales can, in certain circumstances, increase the impact of adverse price movements on the portfolios. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, resulting in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase. Small & Medium Cap Company Risk - securities of companies with small and medium market capitalizations are often more volatile and less liquid than larger companies' investments. Small and medium-cap companies may face a higher risk of business failure, increasing the client's portfolio's volatility. While smaller companies generally have the potential for rapid growth, they often involve higher risks because they may lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, in many instances, trading frequency and volume may be substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to broader price fluctuations. Stocks - there are numerous ways of measuring the risk of equity securities, also known simply as "equities" or "stock." In very broad terms, the value of a stock depends on the company's financial health issuing it. However, stock prices can be affected by many other factors, including but not limited to the class of stock, such as preferred or common, the health of the issuing company's market sector, and the economy's overall health. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap"), but the sheer size of an issuer is not, by itself, an indicator of the safety of the investment. Stock Funds - although a stock fund’s value can rise and fall quickly (and dramatically) over the short term, stocks have performed better over the long term than other types of investments—including corporate bonds, government bonds, and treasury securities. Overall, “market risk” poses the most significant potential danger for investors in stock funds. Stock prices can fluctuate for various reasons, such as the economy's overall strength of demand for products or services. Stock Market Risk - the market value of stocks will fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term because of factors affecting individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. Strategy Restrictions Risk - individual institutions may be restricted from directly utilizing some investment strategies the Adviser may engage. Such institutions, including entities subject to ERISA, should consult their advisors, counsel, and accountants to determine what restrictions apply and whether certain investments are appropriate. Strategy Risk - an adviser's investment strategies and techniques may not work as intended. Structured Products Risk - a structured product, also known as a market-linked product, is generally a pre- packaged investment strategy based on derivatives, such as a single security, a basket of securities, options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent, swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a fixed maturity and have two components: a note and a derivative. A derivative component is often an option. The note provides periodic interest payments to the investor at a predetermined rate, and the derivative component provides for the payment at maturity. Some products use the derivative component as a put option written by the investor that gives the buyer of the put option the right to sell the security or securities at a predetermined price to the investor. Other products use the derivative component to provide for a call option written by the investor that gives the buyer the right to buy the security or securities from the investor at a predetermined price. A feature of some structured products is a "principal guarantee" function, which offers protection of the principal if held to maturity. However, these products are not always Federal Deposit Insurance Corporation insured; the issuer may only insure them and thus have the potential for loss of principal in the case of a liquidity crisis or other solvency problems with the issuing company. Investing in structured products involves many risks, including but not limited to fluctuations in the price, level or yield 32  of underlying instruments, interest rates, currency values and credit quality; substantial loss of principal; limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the issuer; conflicts of interest; and, other events that are difficult to predict. Supervision of Trading Operations Risk - an adviser, with assistance from its brokerage and clearing firms, intends to supervise, and monitor trading activity in the portfolio accounts to ensure compliance with firm and client objectives. However, despite their efforts, there is a risk of unauthorized or otherwise inappropriate trading activity in portfolio accounts. Depending on the nature of the investment management service selected by a client and the securities used to implement the investment strategy, clients can be exposed to risks specific to the securities in their respective investment portfolios. Systematic Risks - these are risks related to a broad universe of investments. These risks are also known as non-diversifiable risks, as diversification within the system will not reduce risk if the system loses value. Trading Limitation Risk - for all securities, instruments, or assets listed on an exchange, including options listed on a public exchange, the exchange has the right to suspend or limit trading under certain circumstances. Such suspensions or limits could render specific strategies challenging to complete or continue, subjecting the Adviser to loss. Such a suspension could make it impossible for an adviser to liquidate positions and expose the Adviser to potential losses. Turnover Risk - at times, the strategy may have a higher portfolio turnover rate than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect an account's performance. Undervalued Securities Risk - identifying investment opportunities in undervalued securities is complex, and there are no assurances that such opportunities will be successfully recognized or acquired. While undervalued securities can sometimes offer above-average capital appreciation opportunities, these investments involve high financial risk and can result in substantial losses. Returns generated may not compensate for the business and financial risks assumed. Unsystematic Risks - these are risks uniquely related to a specific investment. Also known as "diversifiable risks," theoretically, diversifying different investments may reduce unsystematic risks significantly. Warrants - a warrant is a derivative (security that derives its price from one or more underlying assets) that confers the right, but not the obligation, to buy or sell a security – typically an equity – at a specific price before the expiration. The price at which the underlying security can be bought or sold is the exercise or strike price. Warrants that confer the right to buy a security are called warrants; those that confer the right to sell are known as put warrants. Warrants are in many ways similar to options. The main difference between warrants and options is that warrants are issued and guaranteed by the issuing company, whereas options are traded on an exchange and are not issued by the company. Also, the lifetime of a warrant is often measured in years, while the lifetime of a typical option is measured in months. Warrants do not pay dividends or come with voting rights. Withdrawal of Capital Risks - an Offering Memorandum's withdrawal provisions usually restrict the ability to withdraw funds from the funds, private placement, or LP interests. Investors' substantial withdrawals within a short period could require a fund to liquidate securities positions and other investments more rapidly than would otherwise be desirable, reducing the value of the fund's assets and disrupting the fund's investment strategy. Risks of Specific Securities Utilized While Integrated and/or Adviser seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains - they should not invest unless they can bear these losses. 33  Digital Assets & Bitcoin - Integrated and/or Adviser may provide advice regarding digital assets, including cryptocurrencies such as Bitcoin. Digital assets are issued or transferred using distributed ledger or blockchain technology and may include virtual currencies, coins, tokens, or related investment vehicles. These assets are not backed by any central authority, government, or tangible assets; their value is determined by market supply and demand, adoption, and participant sentiment. Investments in digital assets and Bitcoin are highly speculative and subject to significant price volatility, regulatory uncertainty, and unique risks not present in traditional securities or currencies. Regulatory oversight of digital assets is evolving, and investors may not benefit from the protections applicable to registered securities or commodity products. Clients should carefully consider these risks and consult with their Adviser Representative before investing in digital assets or Bitcoin. Options Contracts - options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are very similar to having a short position on a stock. Buyers of puts hope that the stock price will fall before the option expires. Selling options is more complicated and can be even riskier. The option trading risks about options buyers are: - Risk of losing your entire investment in a relatively short period of time. - The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). - European-style options that do not have secondary markets on which to sell the options before expiration can only realize their value upon expiration. - Specific exercise provisions of a specific option contract may create risks. - Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks for options sellers are: - Options sold may be exercised at any time before expiration. - Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock. - Writers of Naked Calls risk unlimited losses if the underlying stock rises. - Writers of Naked Puts risk substantial losses if the underlying stock drops. - Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. - Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how leverage in options can work against the options trader. - Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. - Call options can be exercised outside of market hours such that the writer of those options cannot perform effective remedy actions. - Writers of stock options are obligated under the options that they sell even if a trading market is not available or if they are unable to perform a closing transaction. - The value of the underlying stock may surge or decline unexpectedly, leading to automatic exercises. 34  Other option trading risks are: - The complexity of some option strategies is a significant risk on its own. - Option trading exchanges or markets and options contracts are always open to changes. - Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. - Risk of erroneous reporting of exercise value. - - Risks not specific to options trading include market, sector, and individual stock risks. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Futures - futures are financial contracts obligating the buyer to purchase an asset (or the seller to sell an asset), such as a physical commodity or a financial instrument, at a predetermined future date and price. The primary difference between options and futures is that options give the holder the right to buy or sell the underlying asset at expiration, while the holder of a futures contract is obligated to fulfill the terms of their contract. Buyers and sellers in the futures market primarily enter into futures contracts to hedge risk or speculate rather than to exchange physical goods. Futures are not only for speculating. They may be used for hedging or may be a more efficient instrument to trade than the underlying asset. Neither Integrated nor the Adviser represent or guarantee that the services provided or any analysis methods provided can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including many above) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Investing also risks missing out on more favorable returns that could be achieved by investing in alternate securities or commodities. Any above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax, or legal consequence. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Clients are advised that investors could lose money over short or even long periods and investing in securities involves the risk of losing the entire principal amount invested, including any gains. Clients should not invest unless they can bear these losses. Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. Our use of AI primarily focuses on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. 35  It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of client or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. (For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality.) Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach in adopting and implementing AI technologies. Moreover, using AI could lead to litigation and regulatory risk exposure. To mitigate these risks, we implement stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Further, additional risks may also be disclosed for different Integrated advisory groups. Before acting on any analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to carefully refer to all disclosure documents and direct any questions regarding risks, fees, and costs to their Adviser Representative. Item 9 – Disciplinary Action Registered investment advisers such as Integrated are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. On September 9, 2024, the SEC announced a settlement with Integrated Advisors Network, LLC for violations of the Marketing Rule under the Advisers Act and paid a civil penalty of $325,000. The firm settled the charges without admitting or denying the SEC’s findings. Certain Adviser Representatives of Integrated may also have disciplinary actions or disclosures related to alleged violations of securities regulations, rules, or statutory provisions by federal or state regulatory agencies. Clients and prospective clients may review current disclosure documents for Integrated and its Adviser Representatives on the SEC’s Investment Adviser Public Disclosure (“IAPD”) website at www.adviserinfo.sec.gov. To search for information about the firm, enter “Integrated Advisors Network, LLC” or CRD #171991. To review information about individual Adviser Representatives, use their name or CRD number in the search function. Copies of disclosure documents are also available by contacting Integrated at 855.729.4222 or by visiting www.integratedadvisorsnetwork.com. Item 10 – Other Financial Industry Activities and Affiliations Integrated offers services through their network of IARs. IARs may have their own legal business entities whose trade manes and logos are used for marketing purposes and may appear on marketing materials or client statements. The client should understand that the business are legal entities of the IAR and not of Integrated. The IARs are 36  under the supervision of Integrated, and the advisory services of the IAR are provided through Integrated. Integrated has the arrangement described above with the IARs of ZWAG LLC. Integrated is an independent registered investment adviser that provides only investment advisory services. The firm does not engage in any other business activities, offer services other than those described herein, or maintain any relationship or arrangement material to our advisory business with any of the following entities: 1. broker-dealer, municipal securities dealer, government securities dealer or broker, 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), 3. other investment adviser or financial planner, 4. futures commission merchant, commodity pool operator, or commodity trading adviser, 5. banking or thrift institution, 6. accountant or accounting firm, 7. a lawyer or law firm, 8. insurance company or agency, 9. pension consultant, 10. real estate broker or dealer, and 11. sponsor or syndicator of limited partnerships. Designations Integrated Associates can hold various other designations in connection with the approved outside business activities, separate from their role with Integrated. Integrated does not solicit clients to utilize any services offered by Associates in this capacity. Advisers’ recommendations or compensation for such designation services are separate from Integrated’s advisory services and fees. Promoter Relationships Integrated has entered a promoter relationship with a qualified individual who is paid to refer clients to the Adviser, which can result in the provision of investment advisory services. Integrated ensures any promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed promoters may only provide impersonal investment advice by recommending our services and not comment on using the Adviser's services or portfolio construction. The terms of all promoter arrangements are defined by a contract between the promoter and Integrated which sets forth the term of the Agreement and form of compensation to the promoter, which is a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Adviser receives an economic benefit, as the payment received could incentivize the promoter's referral. Accordingly, promoters are required to disclose to referred clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Integrated can also serve as Promoter to the third-party money managers it engages for its Managed Account Solutions (“MAS”) Program services for advisory, administrative, and/or technological services. In this capacity, the Adviser will introduce clients for whom the referred manager's services are suitable and appropriate. In connection with such relationships, Promoter fees can range from 0% to 50% and vary based on the executed Solicitor Agreement. Fees shared will not exceed any limit imposed by any regulatory agency. Clients should refer to their TPM Agreement for exact details and amounts. (Please see Item 14: Client Referrals & Other Compensation for additional details.) 37  Apart from our clients' fees, we do not receive any other economic benefits, including sales awards or prizes. Third-Party Money Managers Through its Managed Account Solutions (“MAS”) Program services, Integrated will direct - and sometimes act - as a Promoter while referring prospective clients or clients to outside money managers. Integrated will be compensated via a fee share from those clients who utilize such services. Before selecting any outside manager, Integrated will review the manager to ensure they fit the Adviser’s models' criteria and conduct initial background due diligence. Referred managers are required to be registered with an appropriate regulatory body and meet specific criteria before being included as a potential referral for clients. Fees shared will not exceed any limit imposed by any regulatory agency. Referred clients will enter a separate Program Agreement with the referred manager and receive the manager's disclosure documents, which they are encouraged to read. The relationship - including any conflicts of interest involving providing advice, service, or account management style - will be disclosed in each contract between Integrated, the third-party money managers, and the client. Integrated reserves the right to add or delete managers as deemed necessary. Clients should contact Integrated directly for a current list of referred managers under this service. Other Business Relationships Integrated uses third-party resources to help run its business and provide services to its clients, mostly back-office related. Integrated sources these professionals acting in a client’s best interest with fiduciary responsibility while focusing on finding the highest value-add providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise, neither Integrated nor its Associates receive compensation for such use or referrals. Outside of the information referenced herein, neither the adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. While not engaged in any business activities other than those disclosed herein, certain of Integrated’s Associates may sell additional products or provide services outside their roles with the Adviser. Mr. Zimmerman does not have any other financial industry activities or affiliations. Conflicts of Interest Making clients aware of other financial activities, affiliations, designations, relationships, and services presents a conflict of interest since Integrated Associates may have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client need. Integrated addresses this conflict of interest by requiring Associates to always act in each client's best interests when making such recommendations and fully disclose such relationships before the transaction. If offering clients advice or products outside of Integrated, Associates satisfy this obligation by advising and disclosing the nature of the transaction or relationship, their role and involvement in the transaction, and any compensation to be paid and received before transaction execution. When acting in this capacity, the firm’s policy is that Associates communicate clearly to prospective or existing clients that they are not acting on behalf of Integrated, the investment adviser or under any Integrated Investment Management Agreement. Clients are not obligated to act upon any recommendations received, implement any recommended transaction(s) through the Adviser, or purchase any additional products or services offered. The ultimate decision to accept any recommendation and retain products or services remains at the client's sole discretion. Additional details of how Integrated mitigates conflicts of interest can be found in the firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics, which is available for review free of charge to any client or prospective client upon request. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics 38  Integrated has adopted a Code of Ethics which establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that such supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, among other things, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to report their personal securities transactions and holdings quarterly to the Integrated’s Compliance Officer and requires the Compliance Officer to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to Integrated’s Compliance Officer. Each supervised person of Integrated receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received the materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during that year. Clients and prospective clients may obtain a copy of Integrated’s Code of Ethics by contacting the Compliance Officer of Integrated Advisors Network. Participation or Interest in Client Transactions Under Integrated’s Code of Ethics, the Adviser and its managers, members, officers, and employees may invest personally in securities of the same classes as are purchased for clients and may own securities of the issuers whose securities are subsequently purchased for clients. If an issue is purchased or sold for clients and any of the Adviser, managers, members, officers and employees on the same day purchase or sell the same security, either the clients and the Adviser, managers, members, officers or employees shall receive or pay the same price or the clients shall receive a more favorable price. The Adviser and its managers, members, officers and employee may also buy or sell specific securities for their own accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. Participation or Interest in Client Transactions – Pooled Investment Vehicles Integrated and its advisory associates may recommend investments in pooled investment vehicles in which a supervised person has a financial interest. This includes circumstances where a supervised person serves as the sponsor, investment manager, general partner, managing member, or in a similar role with respect to the pooled investment vehicle. As a result, the supervised person may receive compensation or other economic benefits, such as management fees, in connection with client investments in the pooled investment vehicle. This presents a conflict of interest because the supervised person has an incentive to recommend the pooled investment vehicle over other investment options that do not provide the same financial benefit. This conflict is addressed by providing full and fair disclosure to clients and requiring adherence to fiduciary duty to act in the client’s best interest. Personal Trading Integrated and its advisory Associates may buy or sell securities that we recommend to clients or securities that clients have already invested before or after, suggesting them to clients - thus potentially profiting from the recommendations provided. Similarly, our securities orders could be combined with client orders to purchase securities ("aggregated trading"). A conflict of interest exists with these practices because it allows trading ahead of clients and the possible receipt of more favorable prices than a client would receive. To eliminate such conflicts and ensure clients receive preferential treatment, safeguard the equitable treatment of all client orders, and confirm such trading does not affect the markets, Integrated has instituted within its Code of Ethics a trading policy consisting of personal trading and pre-clearance procedures for Associate personal account transactions and a transaction reporting system to monitor policy compliance. Integrated's policy prohibits the firm, its Associates, or any related person from participating in trading that may be detrimental to any advisory client. Associates must disclose, pre-clear, and report specific trades and maintain compliance with the firm's policies and procedures to safeguard that no Associate receives preferential treatment over advisory clients or affects the markets. Integrated performs an Access Person trade review quarterly, annually, and as needed to verify Associate 39  compliance with the firm's trading policies and procedures and confirm no conflicts have occurred. As part of this oversight, Integrated also prohibits insider trading and has implemented additional procedures to monitor Associate observation of the Adviser’s insider trading policy. Associates may buy or sell specific security for their accounts based on personal investment considerations, which the Adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Additional details of how Integrated mitigates conflicts of interest can be found in the Firm's comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review free of charge to any client or prospective client upon request. Aggregated Trading Our Firm or persons associated with our Firm may buy or sell securities for you at the same time we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). A conflict of interest exists in such cases because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Item 12 – Brokerage Practices Preferred Custodians & Brokers-Dealers Neither Integrated nor the Adviser maintains custody of the assets managed on our client’s behalf. Client assets are required to be held in an account at a "qualified custodian," generally a broker-dealer or bank. Clients will decide on their custodian during Investment Management Agreement execution and enter into a separate broker- dealer/custodian client account agreement directly with the custodian of their choice. While Integrated works with multiple custodians and will employ several FINRA-registered broker-dealers, after appropriate due diligence and careful consideration of the brokerage practices disclosed within this section, the Adviser has selected several it will typically recommend as its preferred qualified custodians, including but not limited to Schwab (Charles Schwab & Co., Inc. or "Schwab"), and Fidelity (Fidelity Clearing & Custody Solutions,® providing clearing, custody, or other brokerage services through National Financial Services, LLC or Fidelity Brokerage Services LLC, together with all affiliates, "Fidelity"), each an unaffiliated, SEC-registered broker-dealer, Members FINRA/SIPC. Factors Used to Select & Recommend Custodians & Broker-Dealers Integrated seeks to select and recommend a custodian who will hold client assets and execute transactions on terms most advantageous to other available providers and their services. While the Adviser has designated Schwab, and Fidelity as its preferred custodians, it will occasionally review other custodians to determine their compensation's reasonableness. In studying the topic and selecting a custodian, the firm will make a good faith determination that the amount of the commission charged is reasonable given the value of the brokerage and research services received. The analysis will vary and may include a review of any combination of the following: • • • the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account, ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commissions costs, reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • • 40  • personal money management tools such as electronic fund transfer capabilities, dividend reinvestment • • • • • programs, and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, the custodian’s prior service to our clients and us, and as discussed below, the availability of other products and services that benefit us. • • • Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their client's access to institutional brokerage – trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help the adviser manage or administer client accounts and manage and grow the advisory business. The adviser offers these services at no charge if qualifying amounts of client account assets are maintained with the custodian. (Please contact us directly for current qualifying amount numbers.) Below is a description of some standard support services Integrated can receive from our preferred qualified custodians: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and client assets custody. The investment products available include some the adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. Services available are subject to change at the discretion of each custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to Integrated that benefit us but do not directly benefit our clients or their accounts. These products and services assist Integrated with managing and administering client accounts. They include investment research, both a custodian’s own and that of third parties, which can be used to service all, some or a substantial number of our client accounts and software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts, includes pricing and other market data, facilitate the payment of our fees from our clients’ accounts, and assists with back-office functions, recordkeeping, and client reporting. • provides access to client account data (such as duplicate trade confirmations and account statements), • • • • Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: educational conferences and events, technology, compliance, legal, and business consulting, access to employee benefits providers, human capital consultants, and insurance providers. • • • publications and conferences on practice management and business succession, and • 41  Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custodians can also discount or waive their fees for some of these services or pay all or a part of a third party’s costs. Custody & Brokerage Costs Integrated custodians generally do not charge the firm’s clients' custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on their trades or settling into the custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on Integrated’s commitment to maintaining client assets in accounts at the custodian. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if Integrated had not committed. In addition to commissions, or asset-based fees, custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different broker-dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a custodial account. These fees are in addition to the commissions or compensation clients pay the executing broker-dealer. (For additional details, please refer to each custodian’s specific “Fee Schedule.”) Soft Dollars An investment adviser receives a custodian's soft dollar benefits when receiving research or other products and services in exchange for client securities transactions or maintaining account balances with the custodian. Our preferred qualified custodians will offer various services to us, including custody of client securities, trade execution, clearance and settlement of transactions, platform systems access, duplicate client statements, research- related products and tools, access to the trading desk, and block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts), the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds and individual, institutional money managers, and the use of overnight courier services. Receipt of these economic benefits creates a conflict of interest that could directly or indirectly influence Integrated to recommend a custodian to clients for custody and brokerage services, as we receive an advantage but do not have to produce or pay for the research, products, or services; custody services are paid for as part of the client’s fee. Brokerage and research services provided by broker-dealers may include, among other things, effecting securities transactions and performing services incidental to it (such as clearance, settlement, and custody) and providing information regarding the economy, industries, sectors of securities, individual companies, statistical data, taxation, political developments, legal developments, technical market action, pricing and appraisal services, credit analysis, risk measurement analysis, and performance analysis. Such research services can be received in written reports, telephone conversations, personal meetings with security analysts and individual company management, and attending conferences. Research services may be proprietary - research produced by the broker’s staff or third-party - originating from a party independent from the broker providing the execution services. A conflict of interest exists in making a reasonable good-faith allocation between research services and non-research services because Integrated allocates the costs of such services and benefits between those that primarily benefit us and those that mainly help clients. Certain client accounts may benefit from the research services, which do not pay commissions to the broker-dealer. Receiving brokerage and research services from any broker executing transactions for Integrated’s clients will not reduce the adviser’s customary and usual research activities. The value of such information is indeterminable in Integrated’s view. Nevertheless, the receipt of such research may be deemed to be the receipt of an economic benefit and, although customary, may be considered to create a conflict of interest between Integrated and its clients, as services received from our custodians benefit Integrated because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in accounts at each custodian. This required minimum can give Integrated an incentive to recommend that our clients maintain their accounts with a specific custodian based on our interest in receiving custodial services that benefit our business, 42  rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. In some cases, Integrated may receive non-research administrative or accounting services and research benefits from the broker-dealers' services. When this happens, Integrated will make a good-faith allocation between the non- research and research portions of the services received and pay Integrated money ("hard dollars") for the non- research part. Beneficial Interest in Custodial Services Client transactions and the compensation charged by our custodians might not be the lowest compensation Integrated might otherwise be able to negotiate; clients may pay commissions, markups, or markdowns higher than those other broker-dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e), Integrated may pay a broker-dealer a brokerage commission more than another broker might have charged for effecting the same transaction recognizing the value of the brokerage and research services the broker provides. Because we believe it is imperative to our investment decision-making process to access this type of research and brokerage, in circumstances where we feel the execution is comparable, we may place specific trades with a particular broker-dealer providing brokerage and research services to the firm. Broker-dealers' research services may be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a broker-dealer, as permitted by Section 28(e). Only a few possible firms meet Integrated's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. Integrated’s preferred qualified custodians offer similar soft dollar programs, and as such, we mitigate conflicts of interest by not considering this factor in our selection of appropriate custodians. While we could have the incentive to cause clients to engage in more securities transactions that would otherwise be optimal to generate brokerage compensation with which to acquire such products and services, based on Integrated’s interest in receiving the research or other products or services, rather than on our client’s interests in obtaining the most favorable execution, this conflict is eliminated by having a quantitative investment process that creates trades only when the investment model signals the appropriateness of the transaction. Additional transactions are not made. Furthermore, the clients receive greater access to advanced research and portfolio management tools that improve their service - soft dollar benefits are used to service all client accounts, not only those paid for the benefits. Given the client assets under management, we do not believe that maintaining at least the required minimum of those assets per custodian to avoid paying each quarterly service fee presents a material conflict of interest, as we have confidence our preferred qualified custodian selection is in the best interests of our clients. The scope, quality, and price of the services we receive support the belief that our custodian(s) services do not only benefit only us. Custodial Statements Clients will receive – at a minimum - quarterly account statements directly from the account custodian who maintains their investment assets. Integrated statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of individual securities. Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. (See Item 13 - Review of Accounts for additional details.) Best Execution Integrated acts on its duty to seek “best execution.” As a matter of policy and practice, Integrated conducts initial 43  and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. Integrated seeks to ensure compliance with the client's written Investment Management Agreement (and IPS, if applicable to the type of account opened) and observe best practices. Still, a client may pay a higher commission than another custodian might charge to affect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While Integrated will seek competitive rates, they may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage Sometimes, a client may direct Adviser in writing to use another broker-dealer/custodian to execute some or all transactions for the client’s account. The client will negotiate terms and arrangements for the account with the custodian; neither Integrated nor the Adviser will seek better execution services, better prices, or aggregate client transactions for execution through other custodians with orders for other accounts managed by the adviser. As a result, the client may not achieve the most favorable execution of client transactions; directed brokerage may cost the client money. The client may pay higher commissions or other transaction costs or greater spreads, may not be able to aggregate orders to reduce transaction costs, or may receive less favorable prices on transactions for the account than would otherwise be the case had the client used the adviser’s recommended custodian(s). Subject to its duty of best execution, Integrated may decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. Special Considerations for ERISA Clients A retirement or ERISA Plan client may direct all or part of portfolio transactions for its account through a specific custodian to obtain goods or services on behalf of the Plan. Such direction is permitted provided that the products and services offered are reasonable expenses of the plan incurred in the ordinary course of its business. Otherwise, it would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the Plan. Integrated does arrange for the execution of securities transactions for 401k Plans as a part of this service. Trades are executed directly through employee Plan participation. Investment Allocation & Trade Aggregation Policy Our Firm or persons associated with our Firm may buy or sell securities for you while we or persons associated with our Firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("aggregated trading"). In such cases, a conflict of interest exists because we can trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict of interest, our policy is that neither our Firm nor persons associated with our Firm shall have priority over your account in the purchase or sale of securities. Integrated’s allocation and aggregation processes require fair and equitable treatment of all client orders. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Client Participation In Transactions Adviser makes investment decisions, and trades client accounts in aggregation, particularly when clients have similar objectives. We will seek consistency in our investment approach for all accounts with similar investment goals, strategies, and restrictions. (See Item 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading.) Trading Errors Even with the best efforts and controls, trade errors may happen. If a trade is placed for a client’s account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters (“trade error”), such 44  trade error will be immediately reported internally for prompt review, direction, and action to ensure that the client is not disadvantaged. If a trading error occurs in a client’s account, Integrated’s policy is that its clients' interests always come first. Trade errors will be fixed promptly and efficiently upon discovery to help minimize damages to restore the client’s account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Generally, the client will be reimbursed for any loss incurred due to an Integrated or Adviser trade error. Gains from the trade error will either remain with the client or accumulate in an error account to offset error losses. In all circumstances involving our trade errors, clients will be "made whole.” In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. Integrated’s Chief Compliance Officer is available to address any questions a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create. Item 13 – Review of Accounts No less than annually, as indicated herein and within each client's executed Advisory Agreement, client accounts are reviewed by the Investment Adviser Representative responsible for the account. Integrated’s investment professionals will meet with investment management and supervisory services, ERISA - retirement and employee benefit plan benefit services, and Wrap Fee Program services clients to evaluate their accounts and will discuss, at a minimum, the client's investment objectives and financial situation to verify the suitability of investments, financial plan, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, or changes in the client's financial situation, such as retirement, termination of employment, a physical move, or inheritance. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. Secondary reviews are conducted randomly by a member of Senior Management and/or the CCO. Integrated recommends financial planning and consulting services clients meet annually, at a minimum, to discuss any needed adjustments to the client’s plan. Follow-up interviews are typically made to evaluate and collect client financial data to determine changes in their individual and financial circumstances, including but not limited to a marriage, divorce, birth, death, inheritance, lawsuit, retirement, job loss or disability. Other reviews can be conducted upon client request. Each of the above reviews is conducted as part of Integrated’s contracted services; clients are not assessed additional fees for the assessments. Hourly and fixed fee consulting services clients do not customarily receive follow-up reviews. Reviews are conducted upon client request. Managed Account Solutions (MAS) program services client accounts will undergo reviews according to the referred manager’s internal procedures, as described within the account manager’s Program Agreement and other account opening documents, to safeguard portfolios, allocations, and activities consistent with client objectives and risk parameters. Clients should consult their TPM’s Program Agreement for exact details. Account establishment is not required for educational seminars and workshop services clients. Clients do not receive regular additional reviews beyond the services contracted in the Investment Management 45  Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional reports can be provided on an ad hoc basis. Client Reports Regular Reports At the time of account inception, investment management and supervisory services, ERISA - retirement and employee plan benefit services, and Wrap Fee Program services clients will direct their custodian to send them statements at least quarterly Custodial quarterly reports will describe all activity in the account during the preceding quarter, including holdings, account transactions, contributions, withdrawals, fees and expenses, and the beginning and ending account value of the period. Statements may also include performance, other pertinent, appropriate information, and documents necessary for tax preparation. Statements and reports are sent to the address provided by the client to Integrated and the client’s custodian or a different address to which the client may request they be sent in writing. After the initial report delivery and completion of services, Integrated financial planning and consulting services clients will receive reports summarizing Integrated analysis and conclusions as requested by the client or otherwise agreed to in writing. According to the referred third-party manager’s Program Agreement, accounts managed by Integrated's managed account solutions program services will generally receive reports directly from their referred third-party Program manager, including relevant account and market-related information. Each month clients participating in this service will receive either a written statement or electronic notice via established secure online access from their Program custodian alerting them to statement availability and describing all account activity. Clients should consult their Program Agreement for exact details. Clients do not receive regular additional reviews beyond the services contracted in the Advisory or Program Agreement or as required under Rule 206(4)-2 of the Adviser’s Act. Additional or more frequent reports can be provided according to Integrated Adviser Representative practices or ad hoc. As noted previously, Integrated urges clients to promptly review any statements they receive directly from their custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark as applicable to the type of investments held in the account and any periodic report or information from us. The reports received from Integrated may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of particular securities. Integrated cannot guarantee the accuracy or completeness of any report or any other information provided to the client or Adviser by the custodian or another service provider to the client. Integrated encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their custodian or Adviser directly, or if they do not understand the information in any report, document or statement received, they should promptly, and in all cases before the next statement cycle, report any items of concern to Adviser or Integrated. Unless the client indicates otherwise, by promptly notifying Integrated in writing of concerns regarding statements received, investments Adviser or Integrated makes in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be re-confirmed in writing. Item 14 – Client Referrals and Other Compensation Client Referrals 46  Integrated receives client referrals from current clients, estate planning attorneys, accountants, employees, personal friends and other similar sources. The Adviser does not compensate for these referrals. Third-Party Referrals Integrated has entered into several agreements whereby, after appropriate due diligence, it retains the ability to select, recommend, and provide access to certain independent third-party investment advisers with whom it has entered an agreement to make their services available to guide and/or administer clients’ or prospective clients’ accounts. When referring clients for the services of such outside third-party managers (“TPMs”), Integrated will only refer clients for which it has reasonable grounds for believing the services of the approved TPM are suitable and appropriate and then only to TPMs registered with the Securities and Exchange Commission (“SEC”) or with the applicable state(s) who comply with all applicable securities, investment adviser regulations and laws, and Advisers Act Rules. Integrated will only refer those clients to asset managers if it believes it is in their best interest according to the client's financial circumstances and investment objectives. Integrated is compensated by the referred advisers who receive these referrals via a fee share arrangement between 15% and 50%. Shared fees will not exceed any limit imposed by any regulatory agency. Either party's written notice may terminate the Agreement between the Adviser and the referred third party. These relationships are disclosed in the contract between the Adviser and each third-party adviser and the client or prospective client. At the time of any such activities, Adviser Representatives will disclose such referral arrangements to affected clients, in writing, (1) whether they are a client or a non-client, (2) that they will be compensated for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral and other such disclosures as may be required by the referred manager or state in which the referral takes place. Integrated does not have the authority to accept client(s) on behalf of an outside referred manager. The referred TPM has no responsibility to accept any prospective client referred by Integrated. Any specific advice will be delivered to the client by the referred TPM, not Integrated. The referred managers to whom Integrated recommends clients provide the Adviser with an economic benefit for prospective clients. Although Integrated is incentivized to recommend clients to referred managers, its primary responsibility is ensuring its suitability for referred clients. Integrated is under no obligation to continue referrals to any referred investment manager's services. Other Compensation Outside of the disclosures made herein, neither Integrated nor the Adviser compensates any other individual or firm for client referrals or receive compensation from another third party to provide investment advice. Conflicts of Interest The receipt of compensation by Integrated and its Associates directly or indirectly as described herein, presents a conflict of interest. Participating in these activities for compensation or other benefits may incentivize Integrated or an Associate to recommend products to clients based on the payment, compensation, or benefit received rather than client needs. Further, the objectivity of the advice rendered to advisory clients could be biased. Integrated addresses such conflicts of interest by requiring Associates to disclose any such activity fully, the compensation received, and the relationship. Associates satisfy the requirement by revealing to clients the nature of the transaction or relationship, their role, and any compensation paid to them by the brokerage, insurance, or other firms with which they are affiliated. Integrated makes no assurance that the products or the products of another entity are offered at the lowest available cost. Clients are under no obligation to act upon any Associate's recommendations or affect any transactions through the Associate should they decide to follow the suggestions received. Additional details of how Integrated mitigates interest conflicts can be found in the firm’s comprehensive written compliance supervisory policies and procedures and Code of Ethics. Integrated's Code is available for review for free to any client or prospective client upon 47  request. Item 15 - Custody Custodial Practices Integrated typically does not accept physical custody of a client's securities. Clients will keep all account assets with the custodian of their choosing governed by a separate written brokerage and custodial account agreement between them and an independent and separate qualified custodian who will take possession of all account cash, securities, and other assets. Account checks, funds, wire transfers, and securities will be delivered between the client and the custodian of the record. Neither Integrated nor the Adviser is authorized to withdraw any money, securities, or other property from any client custodial account in the client's name or otherwise. However, Integrated is deemed to have custody of certain client assets solely because one or more of its Investment Adviser Representatives engage in certain activities, such as offering a pooled investment vehicle to certain advisory clients. As a result of this arrangement, the Investment Adviser Representative, or affiliated entity, may serve in a role such as general partner, managing member, or investment manager to the pooled investment vehicle, which gives rise to custody under applicable regulations. Additional information regarding this pooled investment vehicle and related conflicts of interest is disclosed in other sections of this Brochure as applicable. Integrated is provided with the authority to seek deduction of its fees from a client's custodial accounts. This process generally is more efficient for both the client and the Adviser. The client will directly provide written limited authorization instructions - either on the qualified custodian's form or separately, to their custodian and request the custodian provide a "transfer of funds" notice to them at their address of record after each advisory fee payment transfer occurs. Third-Party Transfers If Integrated is granted the authority to effect transactions other than trading within an account, it will be deemed to have custody, as such authorization permits it to withdraw funds from the client’s account. Integrated requires the client to complete and sign the appropriate Standing Letter of Authorization (“SLOA”) or other required documentation when facilitating transfers or distributions. Integrated’s policy ensures it complies with the SEC's conditions outlined in their No-Action Letter of February 21, 2017, intended to protect client assets in such situations. The Adviser will require: 1. 2. 3. the client provides an instruction to the qualified custodian in writing, which includes the client's signature, the third-party's name, and either the third-party's address or the third-party's account number at a custodian to which the transfer should be directed, the client authorizes Integrated, in writing, either on the qualified custodian's form or separately, to direct transfers to the third party either on a specified schedule or from time to time, the client's custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client's authorization, and provides a transfer of funds notice to the client promptly after each transfer, the client can terminate or change the instruction to the client's custodian, 4. 5. Integrated has no authority or power to designate or change the identity of the third party, the address, or any other information about the third party contained in the client's instruction, 6. Integrated maintains records showing that the third party is not a related party of the Adviser or located at 7. the same address as the Adviser, and in writing, the client's custodian sends the client an initial notice confirming the instruction and an annual notice reconfirming the instruction. 48  Currently, Integrated is not subject to an annual surprise audit. Third-party management program services clients will follow the custody and SLOA procedures of the Program manager. Clients should refer to the third-party manager’s Program Agreement for exact details. Item 16 – Investment Discretion Account Management Style Integrated advisory services are offered either on a discretionary or non-discretionary basis. Details of the relationship are fully disclosed before any advisory relationship commences, and each client's executed Investment Management Agreement reflects complete information for the account management style. Discretionary Authority Under discretionary account management authority, Adviser will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell, • determine the amount of security to buy or sell, and • determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management style authority via written authorization granting Adviser complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as Integrated deems appropriate in furtherance of their investment risk profile and IPS, with such changes as the client and their Adviser Representative may agree to from time to time - collectively, the “Investment Guidelines.” Discretionary authority is limited to investments within a client's managed accounts. Clients may impose restrictions on investing in particular securities or types or limit authority by providing written instructions. They may also amend/change such limitations by providing written instructions. Clients will sign a “Limited Power of Attorney” as a stand-alone document or as part of the account opening paperwork through their custodian, and Adviser will only be required to maintain or solicit clients' consent for trades made on positions explicitly discussed during the introductory interview, such as inherited stock that the client would like to hold on to for sentimental reasons or as otherwise specified. In all cases, the discretionary authority will be exercised consistent with the stated investment objectives for the particular client account and remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in written notice to the Adviser. Non-Discretionary Authority Some clients may engage their Adviser Representative to manage securities on a non-discretionary account management authority. Non-discretionary account management authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients may decide not to invest in securities or types of securities and refuse to approve securities transactions. Clients will execute all documents required by Integrated or their custodian to establish the account trading authorization, and Integrated will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client’s investment guidelines, with such changes as the client and their Adviser Representative may agree to from time to time. Under this management style, Integrated must receive approval from the client before placing any trades in the client's account. As a result, until Adviser reaches the client, no transactions will be placed in the client's account(s). 49  Similar to discretionary authority, the non-discretionary authority will remain in full force and effect, notwithstanding the incompetence or disability of the client, until terminated in a written notice to the Adviser. For both account management styles, if clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and Adviser engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed upon investment objectives, Integrated or Adviser reserves the right to cancel the client's Agreement after written notice. Similarly, the client reserves the right to cancel their Agreement with the Adviser according to the Agreement provisions if they so desire. Once an investment portfolio is constructed, Adviser will provide ongoing supervision and rebalancing of the portfolio as changes in market conditions and client circumstances may require. Integrated seeks to undertake minimal trading in client accounts to keep transaction fees, other expenses, and tax consequences associated with trading to nominal levels. Managed account solutions program (“MAS”) services client accounts will typically be managed on a discretionary basis with limited trading authorization according to the Program Agreement executed with the referred manager. Clients should consult their Program Agreement for exact details. Item 17 – Voting Client Securities Proxy Voting Neither Integrated nor the Adviser will ask for or accept voting authority for client securities. Clients will receive proxy material directly from the security issuer or their custodian and maintain the responsibility for exercising their right to vote proxies. Integrated is not obligated to forward copies of class action notices to clients or agents. For accounts subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), the plan fiduciary holds plan account proxy voting authority and responsibility. Proxy voting for plans governed by ERISA must conform to the plan document. If the investment manager is listed as the fiduciary responsible for voting proxies, the obligation will be designated to another fiduciary and reflected in the plan document. While Adviser may assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of providing client information about a particular proxy vote in either of the above situations; it is the client's obligation to vote their proxy. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies & Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisors to clients. Integrated has no obligation to advise, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in these legal proceedings involving securities currently or previously held by the account or securities issuers. The Adviser has no duty to evaluate a client's eligibility or submit a claim to participate in the proceeds of a securities class action settlement, verdict, or obligation to forward copies of notices received to clients or their agents. It is the client’s responsibility to respond to class action suits, claims, bankruptcies, and other legal actions/proceedings involving securities purchased or held in their account and/or to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by the corporate management of issuers whose securities they hold. Neither Integrated nor the Adviser will advise or act for the client in these legal proceedings involving securities held or previously held by the account or the issuers of 50  these securities. Neither Integrated nor the Adviser provide legal advice or engage in any activity that might be deemed to constitute the practice of law or accountancy and is not obligated to forward copies of class action notices received to clients or their agents. Item 18 – Financial Information Balance Sheet Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore does not need to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Integrated, its management, nor the Adviser has any financial conditions that will likely impair its ability to meet contractual commitments to investors. Nor has it been involved in an award or otherwise found liable in an arbitration claim alleging damages in excess of $2,500 or any investment or investment-related activity concerning fraud, false statements or omissions, theft, embezzlement or the other wrongful taking of property, bribery, forgery, counterfeiting or extortion, dishonest, unfair or unethical practices, or found liable in a civil, self- regulatory organization or administrative proceeding involving investment or investment-related activity involving the preceding. Integrated has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years Integrated has no financial impairment that will preclude it from meeting contractual client commitments. The Adviser meets all net capital requirements to which it is subject and has not been the subject of a bankruptcy petition in the last ten years. 51