Ladenburg Thalmann Asset Management Inc.

Ladenburg Thalmann Asset Management Inc. Ladenburg Asset Management Program (LAMP) Wrap Fee Program Brochure SEC File No. 801-54909 640 Fifth Avenue, 4th Floor New York, NY 10019 (800) 995-5267 www.ltam.com This wrap fee program brochure provides information about the qualifications and business practices of Ladenburg Thalmann Asset Management Inc. (“Ladenburg”). Ladenburg is registered with the Securities and Exchange Commission (“SEC”) as a registered investment adviser. Registration does not imply any level of skill or training. If you have any questions about the contents of this brochure, please contact us at (800) 995-5267 or lamp@ladenburg.com. The information in this brochure has not been approved or verified by the SEC or by any state securities authority. Additional information about Ladenburg is also available on the SEC’s website at adviserinfo.sec.gov/firm/summary/108604. 07/30/2026 1  Item 2 – Summary of Material Changes This section provides a summary of material changes that were made to this brochure since the last annual amendment dated March 31st, 2026. Ladenburg may make interim changes to this brochure throughout the year. Each brochure must be filed with the SEC and can be viewed at adviserinfo.sec.gov/firm/brochure/108604. Material Changes: • Item 5: Account Requirements and Types of Clients: This section was amended to reflect updates to the minimum amount of assets required to open an account in the LAMP program. 2  Table of Contents Item 2 – Summary of Material Changes ....................................................................................................... 2 Item 3 –Table of Contents............................................................................................................................. 3 Item 4 – Services, Fees and Compensation .................................................................................................. 4 Consulting Services ............................................................................................................................... 4 Portfolio Management .......................................................................................................................... 4 Execution of Trades ............................................................................................................................... 4 Other Assets .......................................................................................................................................... 5 Custody ................................................................................................................................................. 5 Fees and Compensation ........................................................................................................................ 5 Item 5 – Account Requirements and Types of Clients .................................................................................. 9 Item 6 – Portfolio Manager Selection and Evaluation ................................................................................ 10 Individual Needs of Clients and Restrictions ....................................................................................... 10 Other Types of Accounts ..................................................................................................................... 10 No Performance-based Fees ............................................................................................................... 10 Methods of Analysis, Investment Strategies and Risk ........................................................................ 10 Voting Client Securities ....................................................................................................................... 12 Item 7 – Client Information Provided to Ladenburg ................................................................................... 13 Item 8 – Client Contact with Ladenburg ..................................................................................................... 13 Item 9 – Additional Information ................................................................................................................. 13 Disciplinary Information ...................................................................................................................... 13 Other Financial Industry Activities and Affiliations ............................................................................. 14 Payments from Third Parties .............................................................................................................. 17 Conflicts of Interest ............................................................................................................................. 18 Code of Ethics and Personal Trading .................................................................................................. 18 Review of Accounts ............................................................................................................................. 19 Client Referrals and Other Compensation .......................................................................................... 20 Financial Information .......................................................................................................................... 20 Ladenburg Thalmann Asset Management (“Ladenburg”) - Privacy Notice ................................................ 21 I 3  Item 4 – Services, Fees and Compensation Consulting Services Each client has a Financial Adviser, who may be a Financial Adviser of Ladenburg Thalmann Asset Management Inc. (“Ladenburg”), Osaic Wealth, Inc. Osaic Institutions, Inc. or Osaic Advisory Services, LLC, all of which are affiliates of Ladenburg, as described in “Other Financial Industry Activities and Affiliations” below. The Financial Adviser may also be registered as, or a Financial Adviser of, an investment adviser that is not affiliated with Ladenburg. The Financial Adviser may be a registered representative of Ladenburg Thalmann & Co Inc., (“LTCO”), Osaic Wealth, Inc. or Osaic Institutions, Inc. Clients who wish to participate in the Ladenburg Asset Management Program (“LAMP”) will enter into a LAMP agreement. The LAMP agreement will set forth which investment advisory entity is providing consulting services in connection with the client’s account. Clients inform their Financial Advisers of the investment objectives, risk tolerance, investment time horizon, and any investment policies, guidelines, or reasonable restrictions applicable to the assets they designate for investment through the LAMP Program. Based on the information provided, the Financial Adviser assists the client in determining if there is an appropriate LAMP solution for their investment needs and helps select an investment strategy for the client’s account from those available through LAMP. Portfolio Management A team of investment managers employed by Ladenburg (“LAMP Managers”) manage the accounts in LAMP on a discretionary basis in accordance with the investment strategy that the client selects, and information provided by the client. Any restrictions on the management of an account imposed by a client can cause the LAMP Managers to deviate from the investment decisions they would otherwise make in managing the account. Ladenburg will not have the discretion to select a different investment strategy without the client’s written authorization. in the LAMP program. You can find information about Ladenburg offers a number of other investment advisory products and services that are not described in this brochure. You can find information about these other products and services at www.ltam.com. Ladenburg also manages a series of mutual funds, known as the Ladenburg Funds, which utilize the same five strategies used the Ladenburg Funds at www.ladenburgfunds.com. Execution of Trades A broker-dealer affiliated with Ladenburg, and the Financial Adviser typically executes trades for accounts in LAMP. The specific broker-dealer will be named in the LAMP agreement. If your Financial Adviser is a Ladenburg Financial Adviser and is providing consulting services, the introducing broker-dealer will be LTCO. If an Osaic Wealth, Inc. Financial Adviser is providing consulting services, Osaic Wealth, Inc. will act as broker-dealer. If an Osaic Institutions, Inc. Financial Adviser is providing consulting services, Osaic Institutions Inc. will act as broker-dealer. If a registered broker-dealer representative is registered separately as an investment adviser and providing consulting services, that broker-dealer will generally act as broker- dealer. In certain cases, the Financial Adviser may recommend/require that clients establish brokerage accounts to maintain custody of clients’ assets and to effect trades for their accounts with a broker-dealer that is not affiliated with the Financial Adviser or Ladenburg (“Unaffiliated Broker”). The Unaffiliated Broker will be named in the LAMP agreement. The final decision to select an Unaffiliated Broker is at the discretion of the client, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA account holder. The Unaffiliated Broker may provide the Financial Adviser or Ladenburg with access to its institutional trading and customer services, which may not be available to retail investors. These services are generally available to independent advisers on an unsolicited basis; however, certain Unaffiliated Brokers only provide the services at no charge as long as a designated amount of the adviser’s clients’ assets are maintained in accounts with the Unaffiliated Broker. For example, the Schwab Advisor Services division of Charles Schwab & Co., Inc. (“Schwab”) provides certain services at no charge to advisers as long as a total of at least $10 million of the adviser’s clients’ 4  assets are maintained in accounts at Schwab. This creates a conflict of interest as the Financial Adviser will have an incentive to recommend Schwab or another Unaffiliated Broker over other broker-dealers. The services that may be provided by the Unaffiliated Brokers include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analysis and reports, and access to mutual funds and other investments that may be otherwise generally available only to institutional investors or would require a significantly higher minimum investment. Unaffiliated Brokers can make available other products and services that benefit the Financial Adviser or Ladenburg but may not benefit the clients’ accounts. These benefits may include national, regional or Ladenburg investment adviser specific educational events organized or sponsored by the Unaffiliated Broker. Other potential benefits may include occasional business entertainment, software, research, support functions, and or professional services provided by the Unaffiliated Broker. Thus, a Financial Adviser’s recommendation/requirement that clients maintain their assets in accounts at a particular Unaffiliated Broker can be based in part on the benefit the investment adviser of the availability of certain products and services provided by the Unaffiliated Broker and not solely on the nature, cost or quality of custody and brokerage services provided by the Unaffiliated Broker, which creates a potential conflict of interest. Other Assets In certain limited circumstances, the broker-dealer may permit assets that are not being managed under LAMP to be held in the same brokerage account as the LAMP assets. These assets are referred to as “non- LAMP assets.” Ladenburg will not provide discretionary management of the non-LAMP assets, and the assets will not be taken into account when Ladenburg manages the LAMP assets. Client will typically receive consulting services in connection with the non-LAMP assets from their Financial Adviser and pay fees to their Financial Adviser based on the value of the non-LAMP assets. Custody Ladenburg does not take custody of any client assets. However, certain clients have the option of authorizing Ladenburg to debit advisory fees from their custodial account. All client assets are held by an independent qualified custodian, which may be a broker-dealer, bank or trust company. Clients will receive account statements from the broker-dealer, bank or other qualified custodian holding the clients’ assets at least on a quarterly basis. Clients should carefully review those statements. Clients who also receive account reviews from Ladenburg should compare them to the account statements they receive from the qualified custodian. The account statements received from the qualified custodian are the official statement of clients’ accounts. Any account information provided by Ladenburg is for informational purposes only. Ladenburg may have standing letters of authorization granting it first-party asset movement authority on its clients’ accounts at certain of Ladenburg’s qualified custodians. Ladenburg provides the qualifying Custodian with the client’s authorization in writing. The qualifying Custodian has a record that the client has identified the accounts for which the transfer is being effected as belonging to the client (both sending and receiving accounts). Ladenburg’s authority to transfer client assets between clients’ accounts at the same qualified custodian or between another independent qualified custodian, (which may be a broker- dealer, bank or trust company) in which both have access to the sending and receiving account numbers and client account name(s) are deemed to be first party asset movement and does not constitute custody. Fees and Compensation Each account in LAMP will generally be charged an asset-based fee (“Wrap Fee”) on a quarterly basis. The Wrap Fee will be calculated based on the value of the LAMP assets in the account. The rate or rates used to calculate the Wrap Fee are subject to negotiation between the Financial Adviser and each client. Ladenburg, in its sole discretion, can waive or reduce advisory fees for certain clients, including employees, friends, and family members of the Firm. Consequently, some clients may pay different fees than others for similar services. These fee reductions are based on personal relationships and not on the assets under management or the complexity of the services provided. 5  The actual fee rates paid by the client will be set forth in the client’s LAMP agreement. The maximum annual Wrap Fee rates are: Asset Level Tiers Account Size Range $100,000 $100,001 – $250,000 $250,001 – $500,000 $500,001 - $1,000,000 $1,000,000 – and Up Up to Next $150,000 Next $250,000 Next $500,000 Assets Over Maximum Wrap Fee Rate 1.85% 1.65% 1.45% 1.25% 1.00% The Wrap Fee rate may be either a flat annual fee rate (maximum rate of 1.85%) or will be a blended fee using two or more of the rate tiers set forth above. The blended rate is calculated by charging a lower rate on the assets above the designated tiers. The Wrap Fee will generally be charged in advance. However, certain clients may be charged in arrears. Certain clients may also be charged monthly rather than quarterly. Whether the Wrap Fee is charged in advance or in arrears, or quarterly or monthly, is set forth in the client’s LAMP agreement. Either party at any time upon written notice may terminate the LAMP agreement and a pro rata portion of any Wrap Fee paid by the client in advance will be remitted to the client based on the number of days left in the quarter following receipt of the notice of termination by Ladenburg. When the Wrap Fee is paid in arrears, a pro rata portion of the Wrap Fee will be due by the client based on the number of days elapsed in the quarter prior to receipt of the notice of termination. The Wrap Fee covers the consulting services provided by the Financial Adviser, the portfolio management services provided by Ladenburg, program administrative services, execution of transactions through the broker-dealer named in the agreement and custodial services (unless otherwise agreed between the custodian and the client). Ladenburg‘s portion of the Wrap Fee for portfolio management ranges from 0.00% to 0.30%. If there are any non-LAMP assets in the account, Ladenburg will generally not receive a portion of the Wrap Fee for portfolio management services with respect to those assets. Ladenburg can receive a portion of the fee for administrative services and the Financial Adviser will receive a portion for consulting services. The Wrap Fee charged on non-LAMP assets can be less than the Wrap Fee charges on LAMP assets, as set forth in the client’s LAMP agreement. Osaic Advisory Services, LLC, Osaic Wealth, Inc and Osaic Institutions, Inc can receive a portion of the fee for supervision and administrative services, if one of its Financial Advisers is providing consulting services. If the broker-dealer for the account is LTCO, the broker-dealer will also receive a portion of the Wrap Fee for the execution of transactions and generally pays part of its compensation to the custodian. If the Financial Adviser is independently registered as an investment adviser, the broker-dealer with whom the Financial Adviser is associated can receive a portion of the Wrap Fee for certain administrative services provided. If the client directs Ladenburg to execute transactions through an Unaffiliated Broker, the client may pay a Wrap Fee. If the client pays a Wrap Fee, Ladenburg or the Financial Adviser (or the Financial Adviser’s investment adviser) will generally pay the Unaffiliated Broker a transaction charge for each trade in the account. The cost of these trades is covered by the Wrap Fee. Thus, the Financial Adviser (or the Financial Adviser’s investment adviser) will earn more compensation if fewer transactions are executed for the accounts. In addition, this creates a potential disincentive to trade securities. This conflict of interest is mitigated because the Financial Adviser who pays the cost of the transactions is not managing the account, and the Ladenburg Managers manage these accounts in the same way that they manage accounts that execute through LTCO or another affiliated broker-dealer (see Methods of Analysis, Investment Strategies and Risk below). 6  Certain clients who direct Ladenburg to execute transactions through an Unaffiliated Broker will not pay a Wrap Fee. These clients will pay one fee (“Program Fee”) that covers all of the services covered by the Wrap Fee except for execution of transactions and custodial services, which the client will pay for separately. The client can be charged a separate asset-based fee for execution of transactions through the broker-dealer named in the agreement and for custodial services or the client can pay separate transaction charges and custodial fees. The fee structure will be set forth in the LAMP agreement or in other documents provided to the client. LAMP can cost a client more or less than purchasing such service separately depending on the frequency of trading in the LAMP accounts, commissions charged at other broker-dealers for similar products, fees charged for like services by other advisers and broker-dealers, the fee structure, and other factors. LAMP can also cost a client more or less than purchasing the Ladenburg Funds which offer the same investment strategies through a series of mutual funds. The Wrap Fee does not cover: • Brokerage commissions or other charges resulting from transactions not effected through the broker- dealer named in the client’s LAMP agreement; • Short term redemption fees that may be charged in connection with certain funds (see below) • Any additional custodial services contracted for directly by the client with the custodian; • Certain costs or charges that may be imported by the broker-dealer or custodian named in the client’s LAMP agreement or third parties, including costs associated with exchanging foreign currencies, odd- lot differentials, IRA fees, account transfer fees, exchange fees, wire transfer fees, postage fees, confirmation, statement, prospectus fees and other fees or taxes as required by law. In addition to the Wrap Fee, each mutual fund or exchange-traded fund (ETF) in which a client may invest also bears its own investment advisory fees and other expenses. The mutual funds available through the LAMP Program may be available directly from the funds pursuant to the terms of their prospectuses and without paying the Wrap Fee and exchange-traded funds are available outside of the Program without paying the Wrap Fee, subject to applicable commissions and/or transaction charges. Further, to the extent that cash used for investment through LAMP comes from redemptions of client’s mutual fund or other investments outside of LAMP, there can be tax consequences or additional cost from sales charges previously paid and redemption fees incurred. Such redemption fees would be in addition to the Wrap Fee on those assets. The broker-dealer and/or custodian will receive payments from certain mutual funds (including money market) pursuant to a 12(b)-1 distribution plan or other such plan as compensation for distribution or administrative services and are distributed from the fund’s total assets. These fee arrangements will be disclosed upon request of a client and are available in the applicable fund’s prospectus. LTCO and Ladenburg’s other affiliated broker-dealers receive fees in connection with the client assets participating in the Bank Deposit Sweep Program and the Insured Cash Account Program, which fees are in addition to the management fee that Ladenburg receives in connection with such assets pursuant to the client’s advisory contract. When your Program Account is maintained at one of our affiliated broker-dealer’s clearing firms, Pershing, LLC (“Pershing”) or National Financial Services, Inc. (“NFS”), your free credit balance will be automatically deposited or “swept” to a deposit account at one or more banks whose deposits are insured up to applicable limits by the Federal Deposit Insurance Corporation (“FDIC”) (the “Sweep Program”). Under the Sweep Program, our affiliated broker-dealers, maintain two FDIC-insured deposit programs, the Bank Deposit Sweep Program (“BDSP”) and the Insured Cash Account Program (“ICAP”), that create financial benefits for our affiliated broker-dealers as described below. For certain Program Account types, free credit balances are swept to a money market mutual fund product (the “Money Market Mutual Fund 7  Program”). Please see the Sweep Program Terms and Conditions document, available from your Financial Adviser or from the website listed below, for full details about the Sweep Program. As set forth in the terms of your Customer Agreement with our affiliated broker-dealer, you may remove your Program Account from participating in the Sweep Program by notifying your Financial Adviser. If you remove your Program Account from the Sweep Program, cash balances will be held by the clearing firm as a free credit balance. In addition, there are always alternatives for the short-term investment of cash balances, including non-sweep money market mutual funds, treasury bills, and brokered certificates of deposit, that offer higher returns than the sweep options made available to you. FDIC Insured Deposit Program (BDSP & ICAP) Eligible account types: all accounts except ERISA Title 1 accounts, 403(b)(7), & Keogh plans. Free credit balances swept to a deposit account will earn interest that is compounded daily and credited to your Program Account monthly. Interest begins to accrue on the date of deposit with the banks participating in the program (“Program Banks”), through the business day preceding the date of withdrawal from the deposit account. The daily rate is 1/365 (or 1/366 in a leap year) of the posted interest rate. Bank Deposit Sweep Program-BDSP Our affiliated broker-dealers have established deposit levels or tiers which ordinarily pay different rates of interest depending on deposit balances. Generally, Program Accounts with higher deposit balances receive higher rates of interest than accounts with lower balances. The interest rate payable to you is determined by our affiliated broker-dealers and is based on the amounts paid by the Program Banks to obtain the deposits. The amount our affiliated broker-dealers retain, less a fee paid to the clearing agent and the third- party administrator, will not exceed 600 basis points (6.00%) per year (the “Maximum Program Fee”) on the average daily balances held in the BDSP. Interest paid on the deposit accounts will always be lower than the rate of return on (i) other investment products that are not FDIC insured, such as money market mutual funds and (ii) on bank deposits offered outside of the BDSP. Ladenburg and your Financial Adviser do not receive any portion of the fees paid by the Program Banks. The income our affiliated broker-dealers earn from Program Banks based on your balances in BDSP will in almost all circumstances be substantially greater than the amount of interest you earn from the same balances. As such, our affiliated broker-dealers receive a substantially higher percentage of the interest generated by deposit balances in the BDSP than the interest credited to your accounts. When evaluating whether to utilize the Sweep Program and the extent to which the fee exceeds the interest rate you receive, you should assume that our affiliated broker-dealers are receiving the Maximum Program Fee as described above. Insured Cash Account Program - ICAP Our affiliated broker-dealers will receive a monthly per-account fee for services it provides in connection with maintaining and administering the Sweep Program for IRAs held in an advisory/ fee-based account (the “Sweep Account Fee”). The Sweep Account Fee that each of our affiliated broker-dealers can earn from Program Accounts participating in ICAP is subject to a maximum monthly per account fee that is between $30.25 and $34.50. Please refer to the applicable Sweep Program Terms and Conditions document, which you can obtain from your Financial Adviser or from the website listed below; refer to “Disclosures,” then to the FDIC Insured Deposit Program used in your account (ICAP), for further details about the maximum monthly per account fee. The Sweep Account Fee does not depend on or vary with (and is not affected by) the actual amounts held in any particular account or your Program Account. Thus, the compensation for Program Accounts that participate in ICAP is composed solely of the Sweep Account Fee. The fee received may differ among each Program Bank. You will have no rights to the amounts paid by the Program Banks, except for interest actually credited to your account. The Sweep Account Fee will reduce the interest you are paid on the amount of assets in your Program Account. 8  The Sweep Account Fee will generally be paid by the Program Banks on your Program Account’s behalf; however, the Fee or any portion thereof can be deducted directly from your Program Account if, for example, the amounts paid by the Program Banks are insufficient to cover the Sweep Account Fee. In the event that we debit all or a portion of the monthly account fee from your account, each such amount will be reflected on your account statement. The amount of fees received by our affiliated broker-dealers, the clearing agent, and any other service provider reduces the interest you receive on your deposit account(s). Ladenburg and your Financial Adviser do not receive any portion of the fees paid by the Program Banks. Because the Sweep Program generates significant payments from third parties (i.e., the Program Banks that participate in BDSP and/or ICAP) to our affiliated broker-dealers, a conflict of interest exists. A conflict of interest also arises because our affiliated broker-dealers earn more compensation from cash balances being swept to or maintained in the Sweep Program than if you purchase other investment funds or securities. The more client deposits held in BDSP, and the longer such deposits are held, the greater the compensation our affiliated broker-dealers, the clearing firms, and the third-party administrator receive. By investing through an advisory account, the compensation our affiliated broker-dealers receive from the BDSP or ICAP, as applicable, is in addition to the advisory fees that you pay. This means that our affiliated broker- dealers earn two layers of fees on the same cash balances in client advisory accounts with them. In addition, a conflict of interest arises as a result of the financial incentive for our affiliated broker-dealers to recommend and offer a Sweep Program over which they have control of certain functions. Our affiliated broker-dealers have the ability to establish and change interest rates paid on Sweep Program balances, to select or change Program Banks that participate in the BDSP and ICAP, and to determine the tier levels (if applicable) at which interest rates are paid, all of which generates additional compensation for our affiliated broker-dealers. Our affiliated broker-dealers maintain policies and procedures to ensure recommendations made to you are in your best interest. For additional information about the Sweep Program for accounts custodied at Pershing and NFS, please visit our website located at https://osaic.com/disclosures/cash- sweep-program Other forms of compensation that LTCO, Ladenburg’s Financial Advisers acting in their capacity as LTCO registered representatives, and/or Ladenburg’s other affiliated broker-dealers can earn in connection with the sale of investment products recommended to clients by Ladenburg are described in the “Other Financial Industry Activities and Affiliations” section below. Item 5 – Account Requirements and Types of Clients The minimum amount of assets required to open an account in LAMP will vary depending on the investment strategy selected as follows: Investment Strategy Minimum Assets Managed Mutual Fund Strategies $5,500 Ladenburg American Funds® Core Strategies $5,500 Ladenburg Franklin Templeton Strategies $5,500 Managed ETF Strategies $5,500 Buffered ETF Strategy $5,500 Future Horizon Strategies $5,500 Tax Sensitive Strategies $5,500 Specialty Strategies $5,500 9  Ladenburg may waive these minimums under certain circumstances. Should the market value of an account fall below the stated minimum, Ladenburg will have the right to require that additional monies be deposited to bring the account value up to the required minimum or close the account. The following types of clients may participate in LAMP: individuals, including high net worth individuals, including small business owners, pension and profit-sharing plans, including the plan participants, trusts, estates and charitable organizations, corporations or other business entities, Taft-Hartley plans, and not for profit entities. Item 6 – Portfolio Manager Selection and Evaluation Ladenburg is the only portfolio manager available through LAMP. Individual Needs of Clients and Restrictions As described in “Services, Fees and Compensation” above, clients inform their Financial Adviser of their investment objectives, risk tolerance, and investment time horizon and give their Financial Adviser any applicable investment policies, guidelines, or reasonable restrictions. Based on this information, the Financial Adviser assists the client in selecting an investment strategy. Clients may impose restrictions on the investments in their accounts, including designating particular securities or types of securities that should not be purchased for an account. The Financial Adviser will communicate any restrictions imposed by the client to Ladenburg. Ladenburg may reject the restriction or the account if Ladenburg deems the restriction to be unreasonable. A client also may request that Ladenburg manage the client's account in accordance with client-specified investment guidelines or policies or otherwise implement a strategy in the client's account in a manner that may differ from that in which Ladenburg would otherwise implement the strategy in the account. The Financial Adviser will communicate any such instruction to Ladenburg. Ladenburg may either reject these changes or reject the account. In the absence of client-specified investment restrictions, guidelines or policies and/or other modifications to the implementation of a strategy that have been accepted by Ladenburg, Ladenburg will generally manage accounts in a manner very similar to that of other clients who have selected the same strategy. Other Types of Accounts Ladenburg provides advice through other programs and services, which include other Wrap Fee programs. These programs and services are described in different disclosure documents which are available upon request. These programs and services generally are not managed using the same strategies and funds used in LAMP, except that Ladenburg utilizes the same strategies and funds in managing the Ladenburg Funds and except that Ladenburg offers portfolio management services to participants of certain 401(k) plans that are similar to the management provided through LAMP. Other than due to operational issues specific to each 401(k) plan, Ladenburg does not manage these accounts differently than accounts in LAMP. No Performance-based Fees Neither Ladenburg nor any of its supervised persons accepts performance-based fees – that is, fees based on a share of capital gains on or capital appreciation of the assets of a client. Methods of Analysis, Investment Strategies and Risk Ladenburg manages accounts in LAMP using the following types of investment strategies: 1. Managed Mutual Fund Strategies. Clients may select one of five managed mutual fund strategies. These five strategies are aggressive growth, growth, growth & income, income & growth, or income. Each strategy is designed to be consistent with a certain combination of investment objectives, time horizon, and risk tolerance. Within each strategy, there may be multiple investment styles. Each Account in these strategies can consist of approximately 15 mutual funds primarily, Exchange-Traded Funds (“ETFs”) and Exchange-Traded Notes (“ETNs”) secondarily, which 10  encompass the asset classes targeted for that strategy’s asset allocation. The mutual funds, ETFs and ETNs are selected for these strategies based on due diligence conducted by Ladenburg, which evaluates the funds on a variety of performance measures and recommends those with the best ratings for inclusion in the managed mutual fund strategies. Ladenburg periodically reviews each strategy and removes or replaces those funds that no longer meet the qualifications necessary for inclusion in the strategies. 2. Ladenburg American Funds® Core Portfolios. Clients may select one of five mutual fund strategies: These five strategies are aggressive growth, growth, growth & income, income & growth, and income. Each strategy is designed to be consistent with a certain combination of investment objectives, time horizon, and risk tolerance. Accounts utilizing these strategies will have a target allocation of 63% American Funds mutual funds, 35% Ladenburg mutual funds and 2% in cash. Ladenburg will evaluate the portfolios for rebalancing back to the target allocation at least annually or based on extreme market conditions. The mutual funds that are selected for these strategies are within the universe of American Funds mutual funds and based on due diligence conducted by Ladenburg on a variety of performance measures. Ladenburg periodically reviews each strategy to remove or replace those mutual funds that no longer meet the qualifications necessary for inclusion in the strategies. For more information about how we handle affiliated investments (see Conflicts of Interest below). 3. Managed ETF Strategies. Clients may select one of five managed ETF strategies. These five strategies are aggressive growth, growth, growth & income, income & growth, or income. Each strategy is designed to be consistent with a certain combination of investment objectives, time horizon, and risk tolerance. Within each strategy, there may be multiple investment styles. Each Account in these strategies can consist of approximately 15 ETFs primarily and mutual funds, or ETNs secondarily (if an appropriate ETF is not available), which encompass the asset classes targeted for that strategy’s asset allocation. The ETFs, mutual funds and ETNs are selected for these strategies based on due diligence conducted by Ladenburg. This due diligence includes an analysis of the underlying market index on which each ETF or ETN is based, as well as the expense ratio, longevity, liquidity and size of the ETF or ETN. Based on this evaluation, Ladenburg recommends those ETFs and/or ETNs with the best ratings for inclusion in the managed ETF strategies. Ladenburg periodically meets to review each strategy and remove or replace those ETFs and/or ETNs that no longer meet the qualifications necessary for inclusion in the strategies. 4. Tax Sensitive Strategies. Clients may select one of five managed tax sensitive strategies. These five strategies are aggressive growth, growth, growth & income, income & growth, or income. Each strategy is designed to be consistent with a certain combination of investment objectives, time horizon, and risk tolerance. Within each strategy, there may be multiple investment styles. Each Account in these strategies can consist of approximately 15 mutual funds, ETFs or ETNs, which encompass the asset classes targeted for that strategy’s asset allocation. The mutual funds or ETFs and/or ETNs are selected for these strategies based on due diligence conducted by Ladenburg, which evaluates the funds on a variety of performance measures and recommends those with the best ratings and most tax sensitive investment strategies for inclusion in the managed tax sensitive strategies. Ladenburg periodically reviews each strategy and removes or replaces those funds that no longer meet the qualifications necessary for inclusion in the strategies. 5. Specialty Strategies. Clients may select one of the specifically focused strategies: Conservative Income, Enhanced Income, Ultra Income and Buffered ETF. Clients may select a specialty strategy which is designed with a combination of investment objectives, time horizon, and risk tolerance targeted to achieve a certain investment goal. Each Account in these strategies will consist of either a combination or solely comprised of mutual funds and ETFs, which encompass the asset classes targeted for that strategy’s asset allocation. The funds are selected for these strategies based on due diligence conducted by Ladenburg, which evaluates the funds on a variety of performance measures and recommends those with the best ratings for inclusion in the specialty strategies. Ladenburg 11  periodically reviews each strategy and removes or replaces those funds that no longer meet the qualifications necessary for inclusion in the strategies. 6. Ladenburg Franklin Templeton Strategies. Clients may select one of five mutual fund strategies: These five strategies are aggressive growth, growth, growth & income, income & growth, and income. Each strategy is designed to be consistent with a certain combination of investment objectives, time horizon, and risk tolerance. Accounts utilizing these strategies will have a target allocation of 63% Franklin Templeton funds, 35% Ladenburg mutual funds and 2% in cash. Ladenburg will evaluate the portfolios for rebalancing back to the target allocation at least annually or based on extreme market conditions. The funds that are selected for these strategies are within the universe of Franklin Templeton funds and based on due diligence conducted by Ladenburg on a variety of performance measures. Ladenburg periodically reviews each strategy to remove or replace those funds that no longer meet the qualifications necessary for inclusion in the strategies. For more information about how we manage affiliated investments (see Conflicts of Interest below). 7. Future Horizon Strategies (formerly known as Socially Responsible Strategies). Clients may select one of five managed socially responsible strategies. These five strategies are aggressive growth, growth, growth & income, income & growth, or income. Each strategy is designed to be consistent with a certain combination of investment objectives, time horizon, and risk tolerance. Within each strategy, there may be multiple investment styles. Each model in these strategies consists of a diversified core allocation of mutual funds and ETFs that incorporate values-aware and sustainability considerations, supplemented by limited thematic allocations. The core allocation consists of ETFs and mutual funds which are “socially conscious” per Morningstar Direct. The thematic allocations can be categorized as either (i) sustainable themes, which focus on areas expected to deliver environmental and/or societal benefits, or (ii) strategic themes, which focus on areas of structural economic and technological change that may also result in indirect sustainability benefits. Ladenburg periodically reviews each strategy and removes or replaces those ETFs or mutual funds that no longer meet the qualifications necessary for inclusion in the strategies.. Ladenburg employs a regimen of quantitative and qualitative investment criteria which allows LAMP to analyze potential funds and select funds for inclusion in the strategies available through LAMP. The due diligence process for ETFs, ETNs and mutual funds includes a review of multiple performance metrics, as well as an evaluation of expense ratios, fund longevity, liquidity, and asset size. Below are some of the criteria utilized in selecting funds for the inclusion in the strategies: • Top quartile of performance within its peer group • Positive alpha, which indicates a funds relative performance to the risk being taken by the portfolio manager • Perform well in bear markets • Lead portfolio manager has a minimum of 5 years as head portfolio manager of fund • Have a portfolio composition that is consistent with its corresponding asset class Each investment strategy and fund entail varying degrees of risk. There can be no assurance that a particular investment strategy will be successful or that clients will not suffer losses. Results generated for each account will differ, and the investment advice provided to an individual will differ from client to client. Investment performance is not guaranteed, and Ladenburg’s past performance with respect to a client’s account or other accounts does not predict future performance. Voting Client Securities The designation for voting of proxies for securities will be defined in the respective Ladenburg -Lamp client agreement, under the section “Proxies”. If Ladenburg is delegated to vote proxies for securities in the 12  accounts, (as per the respective Ladenburg client agreement) it will do so, in accordance with Ladenburg’s policies and procedures regarding proxy voting. This delegation to Ladenburg may be revoked at any time by written notice to Ladenburg. These proxy voting policies and procedures contain guidelines that Ladenburg follows in order to minimize conflicts of interest and to ensure that it votes proxies in a manner consistent with the best interests of its clients. A copy of these policies and procedures is available upon request. Further, clients may obtain information from Ladenburg on how their proxies were voted by submitting a written request to Ladenburg. Item 7 – Client Information Provided to Ladenburg As described in Services, Fees and Compensation above, clients inform their Financial Adviser of their investment objectives, risk tolerance, and investment time horizon and give their Financial Adviser any applicable investment policies, guidelines, or reasonable restrictions. Based on this information, the Financial Adviser assists the client in selecting an investment strategy. The Financial Adviser informs Ladenburg which strategy the client has selected in the account opening paperwork. The Financial Adviser also provides Ladenburg with information about the client. The Financial Adviser is responsible for communicating any changes to the investment strategy selected or client information to Ladenburg. Clients may impose restrictions on the investments in their accounts, including designating particular securities or types of securities that should not be purchased for an account. The Financial Adviser will communicate any restrictions imposed by the client, or any changes to these restrictions that the client makes, to Ladenburg. Ladenburg may reject the restriction or the account if Ladenburg deems the restriction to be unreasonable. A client also may request that Ladenburg manage the client's account in accordance with client-specified investment guidelines or policies or otherwise implement a strategy in the client's account in a manner that may differ from that in which Ladenburg would otherwise implement the strategy in the account. The Financial Adviser will communicate any such instruction, or changes made by the client to such instruction, to Ladenburg. Ladenburg may either reject these changes or reject the account. Item 8 – Client Contact with Ladenburg Clients are encouraged to contact their Financial Adviser to arrange for a consultation with the Ladenburg Managers. Clients are also free to contact Ladenburg Managers directly. Item 9 – Additional Information Disciplinary Information On August 25, 2016, pursuant to an offer of settlement by Ladenburg and as part of an enforcement sweep of 13 investment advisers, the SEC entered an order against Ladenburg (the "Order") making findings -- which Ladenburg neither admitted nor denied -- and imposing sanctions consisting of a cease-and-desist order and a civil money penalty. The Order indicates that Ladenburg violated Section 206(4) of the Investment Advisers Act of 1940 (“Advisers Act”) and rule 206(4)-1(a)(5) thereunder by incorporating into certain advertisements for the Alpha Sector strategies offered through an Ladenburg wrap-fee program some inaccurate performance information provided by F-Squared Investments, Inc. (“F-Squared”), without having a reasonable basis to conclude that the information was true. The Order also indicates that Ladenburg violated the Advisers Act’s recordkeeping provisions by failing to maintain records to substantiate the advertised performance information supplied by F-Squared. The Order acknowledges that Ladenburg’s wrap-fee brochure disclosed that Ladenburg did not verify performance information supplied by third-party managers used in the wrap-fee program. For more information about any disciplinary events that are material to an evaluation of our affiliates listed below in Other Financial Industry Activities and Affiliations section, or a separately registered adviser, please see their disclosure brochure. 13  Other Financial Industry Activities and Affiliations Ladenburg Thalmann Asset Management Inc. (“Ladenburg”) is an investment advisory firm and has been in business since October 29th, 1982. Ladenburg is a wholly-owned subsidiary of Osaic Holdings, Inc., which is indirectly owned primarily by a consortium of investors through RCP Artemis Co-Invest, L.P., an investment fund affiliated with Reverence Capital Partners LLC. RCP Artemis Co-Invest, L.P. is controlled by various other entities including RCP Artemis Co-Invest GP, LLC, RCP Opp Fund II GP, L.P., RCP Genpar L.P., RCP Genpar Holdco LLC, MRB ICBC LLC, and The Berliniski Family 2006 Trust. Osaic Holdings, Inc. owns both Ladenburg and LTCO, a registered broker-dealer. As explained in the Fees and Compensation section above, LTCO can execute trades on behalf of clients who receive advisory services from Ladenburg. LTCO receives compensation for these brokerage services, which it shares with Ladenburg Financial Advisers who are also registered broker-dealer representatives of LTCO. Ladenburg has the following affiliates, which are wholly-owned subsidiaries of Osaic Holdings, Inc. or wholly-owned subsidiaries of one of Osaic, Inc.’s affiliates. Owned by Osaic Holdings, Inc. Owned by Osaic Holdings, Inc. Owned by Osaic Holdings, Inc. Owned by Osaic, Inc. Ladenburg Thalmann & Co. Inc. (LTCO) Broker/Dealer Osaic Advisory Services, LLC Registered Investment Advisor Premier Trust, Inc. Trust Company Osaic Wealth, Inc. Registered Investment Advisor, Broker/Dealer Highland Capital Brokerage Insurance Company Osaic Institutions, Inc. Registered Investment Advisor, Broker/Dealer Owned by Osaic Holdings, Inc. Owned by Osaic Institutions Holdings, Inc. Ladenburg also has Related Persons, who are under common control of Ladenburg’s parent company, Osaic Holdings, Inc. The following chart details the Related Persons, which are wholly-owned subsidiaries of Osaic, Inc., which is a wholly-owned subsidiary of Osaic Holdings, Inc. Owned by Osaic Holdings, Inc. Owned by Osaic, Inc. Owned by Osaic Holdings, Inc. Owned by Osaic, Inc. Owned by Osaic Holdings, Inc. Osaic, Inc. Holding Company Vision2020 Wealth Management Corp. Registered Investment Advisor Osaic Institutions Holdings, Inc. (OIHI) Holding Company Osaic Services, Inc. Broker/Dealer CW Advisors, Inc. Registered Investment Advisor Ladenburg has Related Persons, who are not under common control of Ladenburg’s parent company, Osaic Holdings, Inc. and are not wholly-owned subsidiaries of Osaic Holdings, Inc. or Osaic Inc. Black Diamond Financial, LLC. (BDF) Registered Investment Adviser 100% owned by Black Diamond Financial Holdings, LLC BDF is solely owned by Black Diamond Financial Holdings, LLC, which in turn is principally owned and controlled by Philip Blancato and Jaime Desmond. Philip Blancato and Jaime Desmond function as CEO and COO of Ladenburg respectively. In certain circumstances, BDF recommends Ladenburg’s advisory 14  services to clients. The recommendation by BDF that a client engage Ladenburg for investment advisory services presents a conflict of interest, as the receipt of compensation provides an incentive to recommend Ladenburg’s services, rather than on a particular client’s need. BDF has policies and procedures to address these conflicts, and no client is under any obligation to engage the services of Ladenburg. Business Operations with Affiliates & Related Persons Some of our business operations involve directing clients to products or services of our Affiliated and or Related Persons. In that case we or our Affiliated/Related Persons can receive compensation when doing so which results in a conflict of interest. Most of our Advisory Representatives are associated with LTCO, Osaic Wealth, Inc., Osaic Institutions as Registered Representatives or Osaic Advisory Services, LLC as an Investment Adviser Representative. Your Advisory Representative will take into consideration all types of accounts/programs that could be offered (i.e., both brokerage and advisory accounts) when making the recommendation of an account and the Affiliated/Related Persons maintain policies and procedures to ensure recommendations made to you are in your best interest. Osaic Wealth, Inc. Osaic Institutions, Inc. and Osaic Advisory Services, LLC (together the “Osaic Firms”) have agreements with Envestnet that allows its Advisory Representatives to offer Third-Party Money Managers to its clients through the Wealth Management Program via the Firms’ custodial relationships. The Wealth Management Program allows clients to establish accounts using Fund Strategist Portfolios, Separately Managed Account Portfolios, Unified Managed Account Portfolios and Strategist Unified Managed Account Portfolios . Ladenburg is among the Third-Party Money Managers that can be recommended to clients through the Wealth Management Program. The Osaic Firms have a conflict of interest when recommending Ladenburg to clients. The Osaic Firms earn more total compensation when a client selects Ladenburg as a Third-Party Money Manager than they would earn if the client selects certain other unaffiliated Third-Party Money Managers. Thus, the Osaic Firms’ Advisory Representatives have a conflict of interest because of an incentive to recommend certain managers over others. The Osaic Firms address these conflicts of interest through policies and procedures that, among other things, require Advisory Representatives to make suitable recommendations, to act as a fiduciary to clients, and to act solely in the clients’ best interests. For more information regarding Osaic Wealth, Inc. Osaic Institutions, Inc. and Osaic Advisory Services, LLC and the programs the investment advisory services and programs they offer, please visit www.adviserinfo.sec.gov and refer to their respective registered investment adviser’s Form ADV Part 2A. Certain principal executive officers of Ladenburg may be employees, officers, or directors of affiliates listed above. These permitted additional responsibilities could be viewed as creating a conflict of interest in that the time and effort of the directors, officers, principals and employees of Ladenburg because they will not be devoted exclusively to the business of Ladenburg and can have conflicts of interest due to their loyalties to the different entities. Certain of Ladenburg’s principal executive officers, members of the Ladenburg investment committee and other individuals who determine investment advice given to clients can be registered representatives of LTCO. Certain Ladenburg programs are also available to clients of Osaic Advisory Services, LLC, Osaic Wealth, Inc. Osaic Institutions, Inc. or Premier Trust. Ladenburg performs investment management, due diligence, sales support and/or other operational services for a portion of the fees paid by the client. Ladenburg Financial Advisers can recommend Premier Trust to provide trust and administrative services. Premier Trust is a Nevada chartered trust company that provides trust, estate planning and administrative services. When making any recommendation, the Financial Adviser first consider whether Premier Trust 15  can adequately service client needs and whether any other efficiencies or benefits will result to the client. Clients are not obligated to follow our recommendations or use Premier Trust’s services. When used, Premier Trust provides full disclosure with respect to its trust and administrative services and related costs. Ladenburg Financial Advisers can recommend Highland Capital Brokerage (Highland) to provide insurance products and services. Highland is an independent insurance brokerage firm that distributes fixed and variable life insurance, disability insurance, fixed and indexed annuities, and long-term care solutions to financial professionals and their clients. Some employees of Highland are also registered with our broker/dealer affiliates. Financial Advisers can receive indirect compensation in the form of rebated fees when recommending and selling Highland products to you. This is a conflict of interest as Financial Advisers have an incentive to recommend and sell these products to you. Ladenburg Financial Advisers can recommend that clients invest in the Ladenburg Funds for which Ladenburg acts as investment adviser, and LTCO acts as distributor. Transactions for the funds are executed through LTCO. For more information see the prospectus. These recommendations create a conflict of interest because Ladenburg and LTCO receive more compensation in connection with the purchase of these investments than they do in connection with the purchase of other investments. In addition, these funds pay fees in connection with services or distribution, such as 12b-1 fees. These fees are paid to LTCO as broker-dealer. As explained above, LTCO acts as a dealer with respect to certain securities, and as such, can execute transactions for Ladenburg clients as principal. As a dealer, LTCO can receive a "mark-up," "mark-down," and/or spread in the net price at which principal transactions are executed. This compensation is in addition to other compensation that client pays to Ladenburg and its affiliates. Thus, Ladenburg has a conflict of interest in recommending or deciding to execute trades through LTCO on a principal basis. Ladenburg addresses this conflict of interest in the following ways. After receiving disclosures about a specific principal transaction with LTCO, clients have the opportunity to reject the transaction before it is completed, to the extent required by applicable law. In addition, Ladenburg has policies and procedures in place to assure that clients receive best execution with respect to principal trades, regardless of whether the trade is executed by LTCO or an unaffiliated dealer. Ladenburg can also recommend that clients invest in securities issued in an initial public and/or secondary offerings (“new issues”) for which LTCO acts as a manager, underwriter and/or a member of the selling group. Ladenburg has a conflict of interest in recommending these securities for several reasons. First, LTCO receives all or a portion of the gross spread – the difference between the price that the client pays for the security and the price that LTCO purchases the security for -- in connection with such sales. This gross spread is generally 7% but can be higher or lower in connection with certain offerings. Ladenburg Financial Advisers generally receive a portion of this compensation as broker-dealer representatives of LTCO. In addition, LTCO has a substantial interest—both financially and with respect to its reputation— in assuring that the offering is successful by having a large number of the securities purchased. Finally, in connection with certain offerings, LTCO has an obligation to purchase and resell a certain number of securities. Thus, because of its affiliation with LTCO, Ladenburg has incentives to recommend investments in these offerings for these reasons, rather than based on a client’s needs. To address these conflicts, Ladenburg has policies and procedures in place to make sure that securities in initial public offerings are recommended only to clients for whom they are suitable given the client’s investment objectives and assets. In addition, clients are given transaction specific disclosure prior to the client’s decision to invest in such securities. Securities acquired in initial public and secondary offerings may be oversubscribed and Ladenburg has policies and procedures in place for the allocation process. Ladenburg can also compensate its Financial Advisers for the costs of marketing, distribution, business and client development and educational enhancement incurred by the Financial Adviser for the promotion of Ladenburg’s services. This compensation may be based on assets under management or otherwise advised. 16  Reverence Capital Partners manages the private investment funds that indirectly own a majority of Osaic Holdings, Inc., which in turn owns the Firm, as well as private investment funds that hold a minority investment in Envestnet. In addition, select management and Financial Advisors own less than 0.5%, indirectly through a Reverence Capital Partners-controlled entity, in Envestnet. As a result, Financial Advisors associated with Osaic Wealth Inc., Osaic Advisory Services, LLC, Osaic Institutions. Inc. and Vision2020 Wealth Management Corp in particular, have an incentive to offer and recommend to you programs that use Envestnet’s services. Osaic Wealth Inc., Osaic Advisory Services, LLC, Osaic Institutions. Inc. and Vision2020 Wealth Management Corp have procedures designed to mitigate this conflict. Payments from Third Parties In addition to the various types of compensation Ladenburg’s affiliates can earn from clients in connection with effectuating the investment advice Ladenburg renders to clients, these affiliates can also receive payments from third parties in connection with services rendered to Ladenburg’s clients. For example, LTCO and other affiliated broker-dealers can receive distribution or service (“trail”) fees from the sale of certain unaffiliated mutual funds (including money market funds) pursuant to a 12(b)-1 distribution plan or other such plan as compensation for distribution or administrative services. These fees are distributed from the fund’s total assets. LTCO can pay a portion of the distribution fees it earns to Ladenburg’s Financial Advisers in their capacity as broker-dealer representatives of LTCO. For certain accounts custodied at NFS, LTCO credits 12b-1 fees received for Ladenburg Financial Advisers back to the client accounts. Ladenburg’s affiliated broker-dealers can also participate in revenue-sharing arrangements based on fees paid by mutual funds to participate in No-Transaction-Fee (NTF) platforms made available by custodians. Ladenburg’s affiliates can also receive payments called “revenue sharing payments” and/or “marketing allowances” from certain product sponsors (“Strategic Partners”) including mutual funds, insurance companies, and Non-Traded products such as Real Estate Investment Trusts (“REITS”). These payments are not shared with Ladenburg’s Financial Advisers. For more detailed information about the products in the Strategic Partners program, you can request the complete disclosure document from your Financial Adviser. Qualified custodians are another source of revenue to Ladenburg’s affiliated broker-dealers. Specifically, NFS and Pershing provide significant compensation to our affiliated broker-dealers in their capacity as introducing broker/dealer to offset its general operating expenses based on the number of accounts and/or account assets held by our affiliated broker dealers. The specific terms of this compensation differ between NFS and Pershing. Certain custodian fees can apply to your brokerage accounts. In some instances, the affiliated broker-dealers pays a portion of the fee charged. In other instances, the affiliated broker-dealers apply a markup to these fees. In this regard, Ladenburg’s affiliates broker-dealers can receive revenue based upon client activity, as well as the amount of assets custodied with these firms. The types of revenue include, but are not limited to, margin interest charges, IRA fees, inactivity fees, 12b-1 trails and other fees set forth in the custodian’s Schedule of Client Fees and Charges. Our affiliated broker-dealers exercise no discretion, nor provide any advice or recommendation in the selection of the Custodian for any specific account or client. As a result, any difference in compensation to our affiliated broker-dealers is based solely on the contracts with the Custodians and your Financial Adviser’s election of a Custodian. Secondly, Financial Advisers do not share in any compensation paid by the custodians to our affiliated broker-dealers. As a result, Financial Advisers have no financial conflict of interest in any recommendation of a Custodian to clients. 17  For more information regarding custodial fees and the above forms of compensation, please see the Disclosures section of the respective affiliated broker-dealer at our Parent Company’s website: https://osaic.com/disclosures for the Pershing and NFS Schedule of Client Fees and Charges. Conflicts of Interest The various compensation arrangements discussed in this section of the Brochure present conflicts of interest for Ladenburg, because they incentivize the firm and its Financial Advisers to select or recommend products that provide such payments. To mitigate these conflicts, Ladenburg prohibits its Financial Advisers and other supervised persons from selecting or recommending any product based solely on payments that Ladenburg, its employees or its affiliates receive in connection with the promotion of that product. Instead, Ladenburg requires Financial Advisers and other supervised persons to advise and make recommendations in clients’ best interests, taking into account clients’ needs, investment objectives and risk tolerances. Ladenburg maintains policies and procedures to ensure recommendations are suitable and require that its Financial Adviser always acts in the client’s best interest. Ladenburg also maintains a supervisory structure to monitor the advisory activities of its Financial Advisors to reduce conflicts of interest. Ladenburg can provide investment advisory services to family, friends, or other individuals at no cost or at a reduced rate. This practice presents a conflict of interest as Ladenburg can have an incentive to favor these clients. However, Ladenburg provides advice based on the best interests of all clients, and this practice does not impact the fiduciary duty owed to any client. The Ladenburg American Funds® Core Portfolios have a target allocation of 35% to affiliated mutual funds for tactical asset allocation purposes. Ladenburg, the manager of the Ladenburg Funds, does not receive any portion of the Wrap Fee. However, Ladenburg receives an internal management fee from the funds. Ladenburg is not affiliated with American Funds. The Ladenburg Franklin Templeton Strategies have a target allocation of 35% to affiliated mutual funds for tactical asset allocation purposes. Ladenburg, the manager of the Ladenburg Funds, does not receive any portion of the Wrap Fee. However, Ladenburg receives an internal management fee from the funds. Ladenburg is not affiliated with Franklin Templeton. Code of Ethics and Personal Trading Ladenburg has adopted a Code of Ethics for all supervised persons of Ladenburg, describing its high standards of business conduct, and fiduciary duty to clients. All supervised persons at Ladenburg must acknowledge the terms of the Code of Ethics and personal securities transactions and holdings annually, or as amended. The Code of Ethics sets forth detailed policies and procedures regarding the personal trading of its personnel. The Code of Ethics also contains policies and procedures to prevent the misuse of material, non-public information by Ladenburg’s officers and employees. A copy of the Ladenburg Code of Ethics may be obtained by writing to: Ladenburg Thalmann Asset Management Inc., 640 Fifth Avenue, 4th Floor, New York, NY 10019. Ladenburg personnel are required to conduct their personal investment activities in a manner that is not detrimental to its advisory clients. Ladenburg personnel are not permitted to transact in securities except under circumstances specified in the Code of Ethics. Ladenburg may give advice, take action, or hold or deal in securities for some clients or accounts, including Ladenburg’s own accounts, which differs or can be similar at times from the advice it gives, action it takes, or securities it holds or deals for other clients. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees of Ladenburg will: (a) observe applicable legal (including compliance with applicable state and federal securities laws) and ethical standards in the performance of their duties; (b) at all times place the interests of clients first while, at the same time, allowing employees to invest for their own accounts; (c) disclose all actual and potential conflicts; (d) adhere to the highest standards of loyalty, candor and care in all matters relating to clients; (e) conduct all 18  personal trading consistent with the Rules and in such a manner as to avoid any actual or potential conflict of interest or any abuse of their position of trust and responsibility; and (f) not use any material non-public information in securities trading. The Code of Ethics also establishes policies regarding other matters such as outside employment, the giving or receiving of gifts, and safeguarding portfolio holdings information. Under the Code certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of Ladenburg’s clients. In addition, the Code requires pre-clearance of many transactions, and restricts trading in close proximity to client trading activity. These pre-clearance requirements and the exceptions are defined in the Code of Ethics. Ladenburg and its employees may not enter orders for accounts in which they have a beneficial ownership interest to benefit from their knowledge of clients’ orders in a particular security (“front- running”). Ladenburg defaults to LTCO’s front running and personal trading policies as the affiliate broker dealer. In addition to those requirements, Ladenburg Access Persons will not be approved to trade in securities that are ETFs and/or Mutual Funds that are held in Ladenburg’s discretionary portfolios within 5 days of a rebalance by Ladenburg. Because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, and to reasonably prevent conflicts of interest between Ladenburg and its clients. Certain clients also may maintain accounts at LTCO for which Ladenburg does not act in an advisory capacity. In providing execution services to these accounts separate and apart from the client’s advisory accounts, LTCO may enter into transactions as principal. These activities are separate and apart from Ladenburg’s advisory services. The Code of Ethics is enforced through compliance monitoring activities and surveillance. In cases where the firm discovers that an employee has violated a firm policy and/or procedure, the firm’s code of business conduct or code of ethics, a state or federal law, regulation of the SEC, or other regulatory agency, the Compliance Department will take appropriate steps to investigate the circumstances and will take action commensurate with the manner of the violation. Such actions could take the form of a written warning to the employee in conjunction with the firm’s Legal Department or be as serious as disciplinary action up to and including termination. Any such investigations will be brought to the appropriate regulator’s attention, if necessary, which can result in a disclosure of the violation on the employee’s U-4 form, if required. Review of Accounts The Financial Adviser is primarily responsible for reviewing the investment objectives, risk tolerance and investment time horizon and any other investment policies, guidelines on an on-going basis to ensure that it continues to be suitable for the client, taking into account any changes to the information provided by the client. Ladenburg generally reviews LAMP accounts at least quarterly. These reviews are performed by Ladenburg’s Investment Committee and Chief Compliance Officer. Ladenburg or Financial Adviser may provide clients with quarterly performance reviews of LAMP accounts. Ladenburg and Financial Adviser may not provide tax advice, and nothing in the performance review should be construed as advice concerning any tax matter. Performance reviews are not a substitute for regular monthly account statements received from the custodian or Form 1099. Performance reviews should not be used to calculate fees or to complete income tax returns. Upon a client's specific request and subject to the relevant firm’s policies and procedures and applicable law, the performance review may include information about assets outside the program. By including any such assets in the performance review, the firm is not undertaking to provide or responsible for providing any services with respect to those assets. 19  Client Referrals and Other Compensation Ladenburg may enter into agreements with third parties that will solicit clients for Ladenburg and receive compensation for solicitation efforts. In such instances, the third-party solicitor will receive either a percentage of, or a set fee from, the fee charged to the client. If a solicitor is used in connection with a client’s account, the structure and arrangement of the solicitation agreement, as well as the compensation paid to the solicitor, will be fully disclosed to the client. This disclosure will be acknowledged in writing by the client when participating in a Ladenburg program. The fee charged to a client is not affected by the use of a third-party solicitor in connection with client accounts, and a client will not be charged any additional fees for the use of such services. Financial Information Ladenburg does not require prepayment of advisory fees six months or more in advance. Ladenburg has never been the subject of a bankruptcy petition. 20  Ladenburg Thalmann Asset Management (“Ladenburg”) - Privacy Notice FACTS What does Ladenburg Thalmann Asset Management Inc. do with your personal information? Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share and protect your personal information. Please read this notice carefully to understand what we do. What? The types of personal information we collect and share depend on the product or services you have with us. This information can include: Investment Performance Information  Social Security Number, Date of Birth, and Income  Assets and Investment Experience  Employment Information and Tax Reporting  Account Transactions and Retirement Assets  How? When you are no longer our customer, we continue to share your information as described in this notice. All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Ladenburg chooses to share; and whether you can limit this sharing. Reasons we can share your personal information Does Ladenburg share? Can you limit this sharing? Yes No For our everyday business purposes – to administer, manage and service customer accounts, process transactions and provide related services for your accounts, it is necessary for us to provide access to personal information with companies affiliated with Ladenburg and to certain nonaffiliated companies. We may share your personal information: To process your transactions, maintain your account, respond to court orders and legal investigations, respond to regulatory requests, or report to credit bureaus or government entities with parent and Affiliate companies of Ladenburg, Inc. including but not limited to: • Ladenburg Thalmann & Co. (LTCO) • Osaic, Inc. and its affiliated companies with nonaffiliated entities that perform services for us or function on our behalf (such as check printing services, clearing broker-dealers, investment companies, and insurance companies) with third -party administrators and vendors for the purposes of providing current and future information on your account (such as transaction history, tax information and performance reporting). For our marketing purposes – to offer our products and services to you Yes No Yes No For joint marketing with other financial companies- Federal and certain state laws give us the right to share your information with banks, credit unions, retirement plans and other financial companies where a formal agreement exists between us and them to provide or market financial products or services to you. However, we will not share your information with these financial companies for marketing purposes if your financial professional is not affiliated with them without your consent, but we may share information with these financial companies where necessary to service your accounts. 21  For our affiliates to market to you Yes Yes For nonaffiliates to market to you No We do not share For customers of Ladenburg and LTCO Yes Yes  If your financial professional terminates his or her relationship with us and moves to a New Firm, we or your financial professional may disclose your personal information to the New Firm, unless you instruct us not to. If you do not want us or your financial professional to disclose your personal information to the New Firm when your financial professional terminates his or her relationship with us, you may request that we and your financial professional limit the information that is shared with the New Firm.  Your personal information may also be shared with certain entities that are owned, controlled by or affiliated with your financial professional, such as an independent insurance agency, accounting firm or independent investment advisory firm.  In the event your financial professional (or his/her estate) agrees with an unaffiliated financial professional or unaffiliated brokerage or investment advisory firm to sell all or some portion of his/her securities, advisory or insurance business, your personal information may be shared with the acquiring financial professional and/or the New Firm. If you live in Alaska, California, Massachusetts, Maine, North Dakota or Vermont, under certain circumstances, we are required as a financial institution to obtain your affirmative consent to share your personal information with a Nonaffiliate. If you live in any state other than those listed, under certain circumstances, you may opt-out of Ladenburg sharing your Personal Information with a Nonaffiliate. If you opt-out you will continue to receive annual privacy notices as required by the SEC. However, you do not need to respond to maintain a previous opt-out designation. Please refer to the “To Limit Our Sharing” section for ways to opt-out. Who We Are Who is providing This Notice? Ladenburg and its Affiliates. Our Affiliates covered under this privacy notice include the following entities:  Ladenburg Thalmann & Co. (LTCO)  Osaic Holdings, Inc. and its affiliated companies. For a copy of Osaic Holdings Inc.’s privacy policy, please visit: osaic.com/disclosures/privacy-policy What We Do To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We train our employees in the proper handling of personal information. We require companies that help provide our services to you to protect the confidentiality of personal information they receive. How does Ladenburg Thalmann Asset Management protect my personal information? 22  We collect your personal information, for example, when you:  Open an account or apply for insurance;  Seek advice about your investments;  Enter into an investment advisory relationship;  Provide account information or  Make deposits or withdrawals from your account. How Does Ladenburg Thalmann Asset Management collect my personal information? We also collect personal information from others, such as credit bureaus, affiliates, or other companies. Federal law gives you the right to limit only: Why can’t I limit all sharing?  Sharing for affiliates’ everyday business purposes – information about your creditworthiness  Affiliates from using your information to market to you  Sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. To the extent you provide health information to Ladenburg for the purpose of applying for insurance products, such information will not be disclosed to nonaffiliated companies for any purpose, except: Other Important Information Use and Disclosure of health information:    to underwrite or administer your insurance policy or related claims as required by law as authorized by you To limit our sharing You may limit the sharing of your personal information ("Opt-Out") by calling 1-800-215- 1570 if you received this privacy notice by regular mail. Please note: When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing. Questions? In the event you decide to Opt-Out, your decision will be recorded as limiting the sharing of personal information for all applicable options. In other words, if you Opt-Out your personal information will not be shared by Ladenburg or an Affiliate: (i) with your financial professional's new broker-dealer in the event he or she leaves Ladenburg or an Affiliate and joins a New Firm or sells his/her securities, advisory or insurance business to a nonaffiliated company; (ii) with affiliated entities of your financial professional or any bank or credit union that your financial professional is affiliated with; and (iii) with Affiliates of Ladenburg that you do not already have an existing relationship with for the purpose of marketing products or services to you. Go to www.ltam.com This Privacy Notice applies to products and services used primarily for personal, family, trusts, corporation or entity and ERISA account purposes. We reserve the right to change this Privacy Notice, and any of the practices described within this policy, at any time. 23