Landolt Securities, Inc.

FORM ADV 2A: FIRM BROCHURE ITEM 1: COVER PAGE March 21, 2026 Landolt Securities, Inc. 900 North Shore Drive, Suite 279 Lake Bluff, IL 60044 Firm Contact: Matthew McKiernan, Chief Compliance Officer Firm Website: www.landoltsecurities.com This Brochure provides information about the qualifications and business practices of Landolt Securities, Inc. If you have any questions about the contents of this brochure, please contact our firm at (847) 838-5151. Alternatively, you may email us at Don@Landoltsecurities.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any State Securities Authority. Additional information about Landolt Securities, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD # 28352. Please note that the use of the term “registered investment adviser” and description of Landolt Securities, Inc. and/or our associates as “registered” does not imply a certain level of skill or training. You are encouraged to review this Brochure for our firm’s associates who advise you for more information on the qualifications of our firm and our employees. 1  Item 2 – Material Changes Landolt Securities Inc. is required to advise you of any material changes to our Firm Brochure (“Brochure”) from our last annual update. We must state clearly that we are discussing only material changes since the last annual update of our Brochure, and we must provide the date of the last annual update of our Brochure. We have the following material changes to report since the last annual update of our brochure filed on July 14, 2025: 1. Landolt Securities Inc. has regulatory assets under management of more than $100 million and is a registered investment adviser with the U.S. Securities and Exchange Commission as of February 23, 2026. 2. Landolt Securities Inc. provides clients with access to the turnkey or third-party asset management programs (TAMPs) of AssetMark, Inc., Orion Portfolio Solutions, LLC, Trinity Capital Management, LLC, and Prairie Capital Management. Our investment adviser representatives (IARs) assist the client to select a model portfolio of securities designed by the TAMP to provide discretionary or non- discretionary asset management services to the client. Clients should refer to the disclosure brochure(s), client agreement, and other account paperwork for each TAMP for more detailed information about the services available under the TAMP’s program. The IAR will provide copies of the recommended TAMP’s disclosure brochure(s), client agreement, and other account paperwork to the client. 2  Item 3 – Table of Contents ITEM 1: COVER PAGE .................................................................................................................................... 1 Item 2 – Material Changes ............................................................................................................................ 2 Item 3 – Table of Contents ............................................................................................................................ 3 Item 4 – Advisory Business ........................................................................................................................... 4 Item 5 – Fees and Compensation ................................................................................................................. 6 Item 6 – Performance-based Fees and Side-By-Side Management.............................................................. 8 Item 7 – Types of Clients ............................................................................................................................... 8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 9 Item 9 – Disciplinary Information ............................................................................................................... 10 Item 10 – Other Financial Industry Activities and Affiliations .................................................................... 10 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 12 Item 12 – Brokerage Practices .................................................................................................................... 13 Item 13 – Review of Accounts..................................................................................................................... 14 Item 14 – Client Referrals and Other Compensation .................................................................................. 14 Item 15 – Custody ....................................................................................................................................... 15 Item 16 – Investment Discretion ................................................................................................................ 15 Item 17 – Voting Client Securities ............................................................................................................... 15 Item 18 – Financial Information .................................................................................................................. 15 Attachment A .............................................................................................................................................. 16 3  Item 4 – Advisory Business A. Description of our advisory firm and our principal owners including how long we have been in business. Landolt Securities, Inc. (hereinafter “Advisor,” “Landolt Securities” or “we”) is dedicated to providing investment management and consulting services to individuals, trusts, estates, corporations and other business entities. We provide clients with a wide array of investment advisory services and we specialize in investment management services. Our firm was formed in the state of Wisconsin and has been in business since 1989. The firm is owned by Don McKiernan. The firm also sells insurance and conducts business as a securities broker-dealer. B. Description of the advisory services we offer. Investment Management Services Advisor provides investment management services to clients wishing to have their investments managed continuously on a discretionary basis. When discretionary authority is granted by a client, Advisor is free to select the securities to buy and sell, the amount to buy and sell, and when to buy and sell. Advisor is available to provide management services to a wide variety of clients including individuals, pension and profit-sharing plans, trusts, estates, corporations, and other entities. Advisor will also provide services on a non-discretionary basis, which requires the Advisor to obtain permission for each trade in advance. Investment management services begin by Advisor assisting each new client in determining the client’s investment objectives. Once a portfolio is established, the Advisor’s portfolio manager then manages each client’s investments in a manner consistent with the client’s objectives and risk tolerance. Clients may impose restrictions on investing in certain securities or types of securities. Advisor also assists each client in establishing a securities account at a brokerage firm which maintains custody of client securities either directly or with the assistance of its clearing firm. Advisors usually recommend clients establish a brokerage account with RBC Capital Markets, LLC (“RBC”), the Advisor’s transaction clearing firm, and most clients typically do so. Besides managing various types of securities for clients, such as common and preferred stocks, mutual funds, annuity subaccounts, warrants, rights, bonds, municipal securities, options and government bonds, a portion of the securities in client accounts may be held in cash or cash equivalents, including money market mutual funds. Advisor’s portfolio managers are inclined to use fundamental analysis when evaluating client securities and making purchases and sales based upon the results of their analysis. They may also consider technical market factors before deciding the appropriate action to take in a client’s account. 4  Advice given to any client may differ from advice given, or the timing and nature of the action taken, with respect to other client accounts. Advisor will make a reasonable effort to follow all investment management restrictions and instructions expressed to the firm by the client. Clients are encouraged to call their portfolio manager at any time if they have questions. Services may be terminated by written notice. When a portfolio manager places securities transaction orders, the securities brokerage firm processing the orders furnishes the client with a confirmation of each transaction. Monthly securities account statements are also provided to each client by the client’s custodian. Advisor does not guarantee the results of its recommendations and losses can occur by following Advisor’s advice. Advisor does not participate in wrap fee programs. Third Party Asset Management Programs We may recommend other investment advisers for clients generally through or Third Party Asset Management Programs (“TAMPS”). Through these TAMPS, our investment adviser representatives (“IARs”) provide ongoing investment advice to clients that is tailored to the individual needs of those clients. As part of these TAMP services, the IAR typically obtains the necessary financial data from the client, assists the client in determining the suitability of the program, assists the client in setting an appropriate investment objective and risk tolerance, and assists the client in opening an account with the TAMP. In addition, depending on the type of program, the IAR is available to assist the client to select a model portfolio of securities designed by the TAMP or select a portfolio management firm to provide discretionary asset management services. It is the third party investment adviser (and not Registrant’s IARs) that has client authority to purchase and sell securities on a discretionary or non-discretionary basis pursuant to the investment objective chose by the client. This authorization will be set out in the TAMP client agreement. The disclosure brochure for the particular TAMP will explain whether clients can impose restrictions on investing in certain securities or types of securities. In particular, we currently offers advisory services through TAMPS sponsored by AssetMark, Inc. (“AssetMark”) Trinity Capital Management, LLC (“Trinity”), Prairie Capital Management (“Prairie”), and Orion Portfolio Solutions, LLC (“Orion”). Clients should refer to the brochure, client agreement, and other account paperwork for each TAMP for more detailed information about the services available under the program. Advisory Program Cost Differentials. 5 We participate in several advisory programs with third-parties, including the TAMP Programs, which charge varying levels of program fees. When a client invests through such advisory programs, an investment advisory or management fee is deducted from the assets placed in that advisory program. The advisory program retains a portion of the program fee, and a portion of the program fee is paid to Landolt Securities and its IAR. The varying levels of program fees provide an incentive or disincentive for Landolt Securities and its IARs  to participate in or to recommend a particular advisory program. The recommendation by a IAR that a client select a particular advisory program presents a conflict of interest, as the IAR’s compensation provides an incentive to recommend a particular advisory program. All clients and prospective clients should be aware of these factors in selecting an advisory program and in negotiating an investment advisory fee. C. Disclosure of the amount of client assets we manage. We manage $105,626,273 in assets under management on a discretionary basis as of March 31, 2025. Item 5 – Fees and Compensation We are required to describe our brokerage, custody, fees, and fund expenses so you will know how much you are charged and by whom our advisory services are provided to you. Our fees are negotiable and based upon the value and type of assets being managed. All fees, including the minimum annual fee, generally conform to the following fee schedule: Quarterly Fee* Quarter-End Account Value Annual Fee .500% .437% .375% 2.00% 1.75% 1.50% $0 - $1,000,000 $1,000,001 - $5,000,000 Over $5,000,000 _____________________ *Subject to a $300 minimum quarterly fee (not to exceed 3% of a client’s assets under management) The fees shown above are for investment management services only. Fees do not cover any transaction, commission, or other service costs. Fees are calculated as a percentage of account assets as set forth on the schedule above. Fees are charged three months in advance based upon the account value as of the end of each three-month period. The values of related accounts may, at the Advisor’s discretion, be combined for fee calculation purposes. Clients may elect to have their account debited as fees occur, or they may elect to receive a bill directly. We bill clients or charge their fees on a quarterly basis. Deposits exceeding $10,000 shall be charged a pro-rated fee from the date of deposit. Partial withdrawal of funds exceeding $10,000 will result in a pro-rated refund of prepaid fees. Upon termination, which can occur by written notice, all unearned prepaid fees are returned to the client. Unearned fees paid in advance will be returned on a pro-rated basis from the date following receipt by the Advisor of the written termination notice. 6 Clients may pay an annual $50.00 custodial fee if the account is for an IRA. The Advisor may also receive mutual fund service fees paid by mutual funds (aka 12b-1 fees). Clients may be charged a transaction fee, typically $20.00 - $40.00 per trade. Please see Item 12 for further clarification. Due to the quarterly minimum fee, a client's annual fee may exceed 2%. Thus, clients should be aware that fees in excess of 2% a year are considered high and similar services may be available at a lower cost from other firms.  Third Party Asset Management Programs For Third Party Asset Management Programs (“TAMPs”), clients pay an advisory fee as set out in the client agreement with the TAMP sponsor. The fee is typically negotiated among the TAMP sponsor, the IAR and the client. The TAMP sponsor establishes a fee schedule or sets a minimum or maximum fee. The TAMP fee schedule will be set out in the Disclosure Brochure provided by the TAMP sponsor. The advisory fee typically is based on the value of assets under management as valued by the custodian of the assets for the account and will vary by program. The advisory fee typically will be deducted from the account by the custodian and paid quarterly in arrears or in advance. The advisory fee is often paid to the TAMP sponsor, who in turn pays a portion to Landolt Securities, Inc. Generally, Landolt Securities Inc. shares between 80% and 90% of our portion of the fee with the IAR based on the agreement between Landolt Securities and the IAR. A TAMP account can be terminated by a party pursuant to the terms outlined in the TAMP client agreement. The TAMP client agreement will explain how clients can obtain a refund of any pre-paid fee if the agreement is terminated before the end of a billing period. There are other fees and charges imposed by third parties that usually apply to investments in TAMP accounts. These types of fees and charges are described below. Absent other arrangements, the client is charged commissions, markups, markdowns, or transaction charges by the custodian who executes transactions in the TAMP account. There are usually custodian related fees imposed by the custodian of assets for the program account. These additional fees and charges will be set out in the TAMP Brochure and the agreements executed by the client at the time the account is opened. If assets are invested in mutual funds, ETFs or other pooled funds, there are two layers of advisory fees and expenses for those assets. The client will pay an advisory fee to the mutual fund manager and other expenses as a shareholder of the mutual fund. The client will also pay the TAMP advisory fee with respect to those assets. The mutual funds and ETFs available in the programs are available for direct purchase. Therefore, clients could avoid the second layer of fees by not using the advisory services of the TAMP and IAR and by making their own decisions regarding the investment. While a mutual fund in a TAMP program account at times pays an asset based sales charge or service fee (e.g., 12b-1 fee) to the custodian on the account Landolt Securities and its IARs are not paid any portion of these fees. If a client transfers into a TAMP account a previously purchased mutual fund, and there is an applicable contingent deferred sales charge on the fund, client will pay that charge when the mutual fund is sold. If the account is invested in a mutual fund that charges a fee if a redemption is made within a specific time period after the investment, client will be charged a redemption fee. If a mutual fund has a frequent trading policy, the policy can limit a client’s transactions in shares of the fund (e.g., for rebalancing, liquidations, deposits or tax harvesting). If a client holds a variable annuity that is managed as part of a TAMP account, there are mortality, expense and administrative charges, fees for additional riders on the contract and charges for excessive transfers within a calendar year imposed by the variable annuity sponsor. If client holds a UIT in a program account, UIT sponsors charge creation and development fees or similar fees. Further information regarding fees assessed by a mutual fund, variable annuity or UIT is available in the appropriate prospectus, which clients can request from the IAR. If the 7 TAMP program is a wrap fee program, clients should understand that the wrap fee can cost  the client more than purchasing the program services separately, for example, paying fees for the advisory services of the TAMP and IAR, plus commissions for each transaction in the account. Factors that bear upon the cost of the account in relation to the cost of the same services purchased separately include the: (1) type and size of the account, (2)types of securities in the account, (3) historical and or expected size or number of trades for the account, and (4) number and range of supplementary advisory and client-related services provided to the client. The investment products and services available to be purchased in TAMP program accounts can be purchased by clients outside of a TAMP program account, through Landolt Securities or through broker-dealers or other investment firms not affiliated Landolt Securities or the TAMP. Other Compensation Some of our supervised persons sell securities and insurance for a commission. In order to sell securities for a commission, our supervised persons are also registered representatives of Landolt Securities Inc., member FINRA/SIPC. They may accept compensation for the sale of securities or insurance products, including distribution or service (“trail”) fees from the sale of mutual funds. You should be aware that the practice of accepting commissions for the sale of securities: 1) Presents a conflict of interest and gives our firm and/or our supervised persons an incentive to recommend investment products based on the compensation received, rather than on your needs. We generally address commissionable sales conflicts that arise: a. b. When explaining to clients that commissionable securities sales creates an incentive to recommend products based on the compensation we and/or our supervised persons may earn, and may not necessarily be in the best interests of the client; When recommending commissionable mutual funds, explaining that “no- load” funds are available through our firm if the client wishes to become an investment advisory client. 2) 3) In no way prohibits you from purchasing investment products recommended by us through other brokers or agents who are not affiliated with us. Does not reduce your advisory fees to offset the commissions our supervised persons receive. Item 6 – Performance-based Fees and Side-By-Side Management The advisor does not charge performance-based fees. Item 7 – Types of Clients Advisor provides portfolio management services to individuals, high net worth individuals, corporate pension and profit-sharing plans, charitable institutions, foundations, endowments, private investment funds, trust programs, and U.S. corporations. 8  The firm does not have a minimum account size but does charge all managed accounts a minimum fee of $300 per quarter. The charge to the client will be either the minimum fee ($300) or the fee rate specified in the management agreement, but not both. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Risks involved with our analysis Generally speaking, client portfolios are structured on a case-by-case basis, based on the investment criteria and risk tolerance the client is comfortable with. Fundamental analysis is the primary method used in evaluating the securities that may be purchased for a client. Fundamental analysis includes an evaluation of a company’s financial statements, customer products and/or services, the markets they operate in, overall economic conditions, interest rates and inflation, to determine whether the security is an appropriate investment at that time. We look to identify the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced or overpriced (indicating a good time to buy or sell). This analysis presents a potential risk as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Risks involved with our investment strategy A majority of client assets are managed in small-cap growth stocks, which generally carry higher risk but also have the potential for higher returns. Small-cap growth stocks typically have greater volatility than large-cap stocks. These companies are usually newer and less established than large-cap companies, typically experience greater changes to revenues and earnings, and sometimes they are not as financially stable as large-cap companies. When implementing a short-term strategy, we would purchase securities with the idea of selling them within a relatively short time (typically held less than one year). We would do this in an attempt to take advantage of conditions that we believe will soon result in a positive price swing in the securities we purchase. When implementing a long-term strategy, we would purchase securities with the idea of holding them for a relatively long time (typically held more than one year). A risk in a long-term strategy is that by holding the security for this length of time, we may not take advantages of short-term gains that could be profitable to a client. Also, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. Risks involved with recommended investments Clients should be aware that investing in securities involves risk of loss that clients should be prepared to bear. While the stock market may increase and your account could see a gain, there is a risk the stock market may decrease, and your account could see a loss. It is important that you understand the risks associated with investing in the stock market and that you are diversified appropriately. All securities recommended by Advisor involve risk, and that losses can occur from using any of Advisor services. All types of securities are considered, but we mainly invest in stocks, bonds, mutual funds, cash/money market, and ETFs. 9  Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of the Advisor or the integrity of Advisor’s management. On May 9, 2013, the Financial Industry Regulatory Authority ("FINRA") accepted the Advisor’s Letter of Acceptance, Waiver and Consent related to broker-dealer activity. FINRA alleged the broker-dealer failed to properly prepare, maintain and report municipal securities transactions. Without admitting or denying the allegations, the broker-dealer agreed to a Censure and Fine in the amount of $12,500. On July 28, 2014, the North Dakota Securities Department sanctioned the broker-dealer for effecting several securities transactions for residents of North Dakota without being registered in the state. The broker-dealer paid a fine of $20,000. On August 10, 2015, FINRA accepted the broker-dealer’s Letter of Acceptance, Waiver and Consent in connection with alleged violations of FINRA rules related to broker-dealer activity. FINRA alleged the broker-dealer failed to properly maintain appropriate net capital minimums and failed to properly prepare, maintain, and report municipal securities transactions in accordance with MSRB rules. Without admitting or denying the allegations, the broker-dealer agreed to a Censure and Fine in the amount of $25,000. On January 16, 2024, FINRA accepted the broker-dealer’s Letter of Acceptance, Waiver, and Consent in connection with alleged violations of FINRA rules related to broker-dealer activity. FINRA alleged the broker-dealer failed to establish, maintain, and enforce a reasonable supervisory system, including written supervisory procedures, to supervise the electronic communications of its registered representatives. Without admitting or denying the allegations, the broker-dealer agreed to a Censure and Fine in the amount of $25,000. Item 10 – Other Financial Industry Activities and Affiliations A. If our firm or our management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker- dealer, the details are as follows: The Advisor is also a broker-dealer and member of FINRA, and all management persons of Advisor are registered with FINRA as Registered Representatives and Principals. The primary business of the Advisor and its representatives is providing security brokerage services to securities account customers, including buying and selling securities as ordered. The Advisor and its representatives will receive customary commissions for the sale of such products, and this creates a conflict of interest. The firm addresses this conflict by noting that clients are under no obligation to act upon any recommendation of the associated persons or effect any transactions through the associated person if they decide to follow the 10  recommendations. Also, clients are free to purchase such products through other brokers or agents not affiliated with the Advisor. B. If our management persons are registered or have an application pending to register as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities, we must disclose this fact. Neither our firm nor any of its management persons is a commodity broker/futures commission merchant, a commodity pool operator, commodity trading advisor or an associated person for the foregoing entities or has an application for registration pending. C. Description of any relationship or arrangement that is material to our advisory business or to our clients that we or any of our management persons have with any related person listed below. We are required to identify the related person and if the relationship or arrangement creates a material conflict of interest with clients, describe the nature of the conflict and how we address it. As licensed insurance agents, our advisory representatives may recommend to clients a variety of insurance products. The Advisor and its representatives will receive customary commissions for the sale of such products and this compensation creates a conflict of interest. The firm addresses this conflict by noting that clients are under no obligation to act upon any insurance recommendation and are never under any obligation to purchase insurance products. D. If we recommend or select other investment advisors for our clients and we receive compensation directly or indirectly from those advisors, we have other business relationships with those advisors, we are required to disclose these practices and discuss the conflicts of interest these practices create and how we address them. 11 Landolt Securities, when appropriate, recommends or selects other investment advisers for its clients through Third Party Asset Management Programs (TAMPs). Through these TAMPS, our investment adviser representatives (IARs) provide ongoing investment advice to clients that is tailored to the individual needs of the client. As part of these TAMP services, the IAR typically obtains the necessary financial data from the client, assists the client in determining the suitability of the program, assists the client in setting an appropriate investment objective and assists the client in opening an account with the TAMP. In addition, depending on the type of program, the IAR may assist the client to select a model portfolio of securities designed by the TAMP or select a portfolio management firm to provide discretionary asset management services. The TAMP (and not Registrant’s IAR) has client authority to purchase and sell securities on a discretionary or non- discretionary basis pursuant to the investment objective chosen by the client. This authorization will be set out in the TAMP client agreement. The Brochure for the particular TAMP will explain whether clients may impose restrictions on investing  in certain securities or types of securities. Typically, the TAMP will deduct its advisory or management fee from the client’s account and share a portion of that fee with Landolt Securities and its IAR. In particular, Landolt Securities currently offers advisory services through TAMPs sponsored by AssetMark, Trinity Capital Management, LLC, Prairie Capital Management, and Orion Portfolio Solutions. Clients should refer to the Brochure, client agreement and other account paperwork for each TAMP for more detailed information about the services available under the program, including any potential conflicts of interest. Our Chief Compliance Officer remains available to address any questions that a client or prospective client may have regarding the above conflict of interest. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Advisor has adopted a Code of Ethics for all supervised persons of the firm describing its high standard of business conduct and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other procedures. Advisor anticipates that, in appropriate circumstances, consistent with clients’ investment objectives, it will cause accounts over which Advisor has management authority to effect, and will recommend to clients, the purchase or sale of securities in which Advisor, its affiliates and/or clients, directly or indirectly, have a position of interest. We believe that if investment goals are similar for clients and for members and employees of our firm, it is logical and even desirable that there be common ownership of some securities. Advisor’s employees and persons associated with Advisor are required to follow Advisor’s Code of Ethics. Subject to satisfying this policy and applicable laws, officers, directors and employees of Advisor and its affiliates may trade for their own accounts in securities which are recommended to and/or purchased for Advisor’s clients. The Code of Ethics is designed to assure that the personal securities transactions, activities, and interests of the employees of Advisor will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code we require pre-clearance of many transactions and restrict trading in close proximity to client trading activity. Nonetheless, 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 Advisor and its clients. Advisor’s clients or prospective clients may request a complete copy of the firm's Code of Ethics by contacting Donald McKiernan at (847) 838-5151. 12  Certain affiliated accounts may trade in the same securities with client accounts on an aggregated basis when consistent with Advisor's obligation of best execution. In such circumstances, the affiliated and client accounts will share commission costs equally and receive securities at a total average price. Advisor will retain records of the trade order (specifying each participating account) and its allocation, which will be completed prior to the entry of the aggregated order. Completed orders will be allocated as specified in the initial trade order. Partially filled orders will be allocated on a pro-rata basis. Any exceptions will be explained on the order. It is Advisor’s policy that the firm will not affect any principal or agency cross securities transactions for client accounts. Advisor will also not cross trades between client accounts. Principal transactions are generally defined as transactions where an advisor, acting as Principal, for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory client. A principal transaction may also be deemed to have occurred if a security is crossed between an affiliated hedge fund and another client account. An agency cross transaction is defined as a transaction where a person acts as an investment advisor in relation to a transaction in which the investment advisor, or any person controlled by or under common control with the investment advisor, acts as broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions may arise where an advisor is dually registered as a broker- dealer or has an affiliated broker-dealer. Item 12 – Brokerage Practices Custodians/broker-dealers will be recommended based on Landolt Securities Inc.’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and Landolt Securities Inc. may also consider their expertise as a clearing firm, their financial strength, reputation, reporting, technology, and ability to work with broker-dealers and investment advisors who have independent contractors and execution pricing. Currently, the Advisor, while acting as a broker-dealer, executes all trades via its clearing firm, which is also the custodian of all accounts. The commissions and transaction fees charged by the clearing firm may be higher or lower that those charged by other clearing firms. Further, the fees charged by the clearing firm or any other designated custodians are exclusive of and in addition to the Landolt investment advisory fees. The Advisor receives no economic benefit from the relationship. Research and Other Soft Dollar Benefits: Landolt does not receive research or other products or services other than execution from a broker-dealer or a third party in connection with client securities transactions (“soft dollar benefits”). Brokerage for Client Referrals: Landolt receives no referrals from a broker-dealer or third party in exchange for using that 13 broker-dealer or third party.  Directed Brokerage: The Advisor will not allow clients to direct us to use a specific broker-dealer to execute transactions as clients use our recommended custodian (RBC Capital Markets, LLC, i.e. clearing broker-dealer). As clients use our specific custodian, the Advisor may be unable to achieve most favorable execution of client transactions and this practice may cost clients more money over using a lower-cost custodian. Landolt Securities Inc. (the Advisor and broker-dealer), have an economic relationship that creates a conflict of interest. As the Advisor and broker-dealer are the same entity, the Advisor manages this conflict by regularly reviewing execution practices and quality of trades provided by the custodian along with regular account reviews. Aggregating (Block) Trading for Multiple Client Accounts: When exercising discretion, Advisor may combine orders for more than one client’s account to form a “block” order for the purpose of obtaining a better price and execution. When a block order is executed, the firm’s clearing firm allocates an average execution price to each customer’s position within the block on a pro-rata basis. Clients should be aware that although Advisor may place a block order, the executing broker may unbundle the order and execute each order for a client’s account on an individual basis resulting in different execution prices to each client. Also, an exact average price may not occur as a result of the brokerage firm applying varying commission discounts to client accounts. Item 13 – Review of Accounts All managed accounts are regularly monitored for asset allocation and security holdings. The securities are compared to the general objective of the account(s) and adherence to specific written requests a client wishes the Advisor to follow. Day-to-day monitoring includes, but is not limited to, asset allocation, security and sector concentrations and relative credit quality of debt securities. Only our Financial Advisors, Principals and Portfolio Managers will conduct reviews. We may review accounts more frequently and the factors that will trigger a review include material market, economic or political events, or changes in the client’s financial situations and as requested by clients. Clients are provided, at least quarterly, with written transaction confirmation notices and regular written summary account statements directly from their custodian. Item 14 – Client Referrals and Other Compensation Advisor does not currently have any client referral relationships. Thus, it does not pay any fee to a third party for making client referrals. Also, as indicated above, the firm does not direct brokerage transactions to any third party in return for client referrals. 14  Item 15 – Custody Advisor does not take custody of client accounts at any time. Custody of client’s accounts are held primarily at the custodian. Clients will receive account statements from the custodian and should carefully review those statements. The Advisor does not take custody with other accounts which receive the safekeeping services provided by the brokerage firm processing the securities transactions ordered by the Advisor. Advisor and its representatives do not have authority to withdraw funds or take custody of client funds or securities, except for payment of advisory fees due Advisor. Item 16 – Investment Discretion Management services may be provided on either a discretionary or non-discretionary basis. When discretion is exercised, Advisor is granted authority in writing from a client through the Investment Management Services Agreement to exercise discretion in the selection of securities to buy and sell the amount of securities to buy and sell and when to buy and sell them without obtaining specific consent from the client for each trade. Advisor will also exercise discretion to liquidate securities in amounts sufficient to cover its bills. When discretion is not exercised, clients are contacted by the Advisor for permission to execute each investment transaction. If Advisor should error in placing an order, it is Advisor’s policy to take action to make the client’s account whole. Item 17 – Voting Client Securities Advisor and its representatives do not vote proxies on behalf of clients who will receive such notices from their account’s custodian. Advisor also does not take any action on legal notices it or a client may receive from issuers of securities held in a client’s managed account. However, it is available to answer questions regarding such notices. If questions arise, contact Advisor at (847) 838-5151. Item 18 – Financial Information Advisor does not receive fees nor require pre-payment of more than $1,200 per client, six months or more in advance, thus no financial statement for Advisor is attached. Registered Investment Advisors are required in this item to provide you with certain financial information or disclosures about Advisor’s financial condition. Advisor has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. 15  Attachment A Our Role and Fiduciary Acknowledgement for Retirement Accounts 1 . Landolt Securities Inc. provides the following acknowledgement for purposes of complying with the U.S. Department of Labor’s (“DOL”) Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”), where applicable. This acknowledgement is effective on February 1, 2022, or such later date as may be set forth by the DOL Fiduciary Acknowledgement. This acknowledgement applies when Landolt Securities 3 to you regarding your Retirement Accounts, we are fiduciaries within the meaning Inc. provides investment advice or recommendations to you regarding retirement and 2 (“Retirement Accounts”). When we provide “investment other tax-qualified accounts advice” of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing Retirement Accounts. When providing investment recommendations, the way we make money creates certain conflicts with your interests, so we operate under a special rule that requires us, to act in your best interest and: • • • • • • Meet a professional standard of care (give prudent advice); Not put our financial interests ahead of yours (give loyal advice); Avoid misleading statements about our conflicts of interest, fees, and investments; Follow policies and procedures designed to ensure that we give advice that is in your best interest; Charge no more than is reasonable for our services; and Give you basic information about our conflicts of interest. Limitations to our Acknowledgement of Fiduciary Status. This fiduciary not acknowledgement is limited to investment advice and recommendations provided by Landolt Securities Inc. to Retirement Accounts only. It does not create an ongoing duty to monitor your accounts or create or modify a contractual obligation or fiduciary status under any state or federal laws other than the retirement laws. Additionally, we are fiduciaries under the retirement laws when we provide: 1 This disclosure is provided to comply with the DOL’s PTE 2020-02. If there is a conflict between this disclosure and your agreement with Landolt Securities Inc., this disclosure will govern. 2 Retirement Accounts include workplace retirement plans, IRAs, such as Traditional, Roth and SEPs, and other similar accounts. 3 Fiduciary investment advice is investment advice for a fee or other compensation rendered on a regular basis pursuant to a mutual understanding that such advice will serve as a primary basis for your investment decision, and that is individualized to the particular needs of your IRA or plan account. 16  • • • • • • general information education General information and education about the financial markets, asset allocations, financial planning illustrations and the advantages and risks of particular investments; General information and education about issues and options that should be considered when deciding whether to rollover or transfer Retirement Account assets to us; Recommendations about investments held in accounts that are not Retirement Accounts or held in accounts at financial institutions other than Landolt Securities Inc. and for which we do not act as broker of record; Recommendations that you execute at another financial institution; Transactions or trades you execute without a recommendation from us, or that are contrary to, or inconsistent with, our recommendation; and Recommendations that do not meet the definition of fiduciary “investment advice” in Department of Labor regulation section 2510.3-21. Plan to IRA Rollovers. We may provide (1) and to you recommendation about the factors you should consider when deciding whether to move retirement assets to that you move your retirement assets to Landolt Securities Inc., or (2) a Landolt Securities Inc. If we provide a rollover recommendation, our analysis of the costs and services of your retirement plan depends on the information you provide to us (or in certain circumstances, information we obtain from third-parties about the plan (or similar types of plans)). IRA Transfers. If Landolt Securities Inc. recommends that you move assets from an IRA at another financial institution to Landolt Securities Inc., we determined that the recommendation is in your best interest for these reasons: • • Greater services and/or other benefits can be achieved with a Landolt Securities Inc. IRA, and The costs associated with a Landolt Securities Inc. IRA are justified by these services and features. Notwithstanding whether a recommendation has been made, for any assets you decide to transfer/rollover from an employee-sponsored plan or move from an IRA at another financial institution now or in the future, you should: (1) evaluate the investment and non- investment considerations important to you in making the decision; (2) review and understand the fees and costs associated with a Landolt Securities Inc. IRA; (3) recognize that higher net fees (if applicable) will substantially reduce your investment returns and ultimate retirement assets; and (4) understand the conflicts of interest raised by the financial benefits to Landolt Securities Inc. resulting from your decision to roll or transfer assets to a Landolt Securities Inc. IRA. 17  Advisory Services. If Landolt Securities Inc. recommends that you add retirement assets to an advisory program at Landolt Securities Inc., we determined it is in your best interest based on your stated investment profile because: • • The account services and features include one or more of the following: ongoing account monitoring, discretionary management, holistic investment advice, access to affiliated/third party managers, and/or automatic account rebalancing; and The asset-based costs associated with Landolt Securities Inc. advisory programs(s) are justified by these services and features. Brokerage Services and Products. If Landolt Securities Inc. recommends that you add retirement assets to a brokerage account (or product) at Landolt Securities Inc., we determined it is in your best interest based on your stated investment profile because: de • minimis The account services and features include one of more of the following: no or account minimums, fees paid on a transactional basis, and the ability to • maintain concentrated and illiquid positions; and The transaction-based costs associated with a Landolt Securities Inc. brokerage account are justified by these services and features. Notwithstanding whether a recommendation has been made, for any assets you decide to move into a brokerage or advisory account, you should: (1) evaluate the investment and non-investment considerations important to you in making the decision; (2) review and understand the fees and costs associated with the account; (3) recognize that higher net fees (if applicable) will reduce your investment returns and ultimate retirement assets; and (4) understand the conflicts of interest raised by the financial benefits to Landolt Securities Inc. resulting from your decision to move assets into the account. You are responsible for updating us if your investment objectives, risk tolerance and financial circumstances change. More information regarding Fees, Services and Conflicts. For a description of our Fees, Services, and Conflicts of Interest, please refer to our Form CRS at LandoltSecurities.com 18