LEGACY CAPITAL WEALTH PARTNERS, LLC

LEGACY CAPITAL WEALTH PARTNERS, LLC FORM ADV PART 2A – DISCLOSURE BROCHURE Item 1 – Cover Page 8315 Cantrell Road Suite 200 Little Rock, AR 72227 (501) 376-7878 This Form ADV 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Legacy Capital Wealth Partners, LLC (“Legacy Capital” or the “Advisor”). If you have any questions regarding the content of this Disclosure Brochure, please do not hesitate to contact the Advisor’s Chief Compliance Officer, Keith Krueger, by telephone at (501) 376-7878 or by email at keithk@legacycapitalwp.com. The information in this Disclosure Brochure has not been approved or verified by the U.S. Securities and Exchange Commission (“SEC”) or by any state securities authority. Legacy Capital Wealth Partners, LLC is a registered investment advisor. Registration with the SEC or any state securities authority does not imply a certain level of skill or training. Additional information about Legacy Capital and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 291960. March 24, 2025  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Legacy Capital. Legacy Capital believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Legacy Capital encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes The following material changes have been made to this Disclosure Brochure since the annual amendment filing on March 19th, 2024: • The Advisor’s Chief Compliance Officer is now Keith Krueger. Please see Item 4.A. for additional information. • The Advisor no longer offers 3(38) services. See Item 4.B. for additional information. Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. You may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 291960. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (501) 376-7878 or by email at keithk@legacycapitalwp.com.  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 A. Description of the Advisory Firm ..................................................................................................... 4 B. Types of Advisory Services .............................................................................................................. 4 C. Client-Tailored Advisory Services ................................................................................................... 6 D. Wrap Fee Programs ............................................................................................................................ 7 E. Assets Under Management ................................................................................................................. 7 Item 5 - Fees and Compensation ................................................................................................................... 7 A. Fee Schedule for Advisory Services ................................................................................................. 7 B. Payment of Fees ................................................................................................................................ 9 C. Other Fees and Expenses ................................................................................................................ 10 D. Prepayment of Fees......................................................................................................................... 10 E. Outside Compensation for Sale of Securities or Other Investment Products to Clients ................ 11 Item 6 - Performance-Based Fees and Side-by-Side Management ............................................................. 12 Item 7 - Types of Clients ........................................................................................................................... 122 Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss ................................................... 133 A. Methods of Analysis and Risk of Loss ......................................................................................... 133 B. Material Risks Involved .................................................................................................................. 13 Item 9 – Disciplinary Information ............................................................................................................... 17 Item 10 – Other Financial Industry Activities and Affiliations ................................................................... 17 Item 11 – Code of Ethics, Participation or Interest in Client Transactions ................................................. 18 A. Description of Code of Ethics......................................................................................................... 18 Item 12 – Brokerage Practices ..................................................................................................................... 19 A. Factors Used to Select Custodians and/or Broker-Dealers ............................................................. 19 B. Trade Aggregation .......................................................................................................................... 23 Item 13 – Review of Accounts .................................................................................................................... 23 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews............................... 23 B. Other Reviews ................................................................................................................................ 24 C. Content and Frequency of Regular Reports Provided to Clients .................................................... 24 Item 14 – Client Referrals and Other Compensation ................................................................................... 24 A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients............................. 24 B. Compensation for Client Referrals ................................................................................................. 26 Item 15 – Custody ........................................................................................................................................ 26 Item 16 – Investment Discretion ................................................................................................................ 277 Item 17 – Voting Client Securities .............................................................................................................. 27 Item 18 – Financial Information .................................................................................................................. 27 A. Balance Sheet.................................................................................................................................. 27 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ............................................................................................................................................. 27 C. Bankruptcy Petitions in Previous Years ......................................................................................... 27  Legacy Capital Wealth Partners, LLC Disclosure Brochure Item 4 - Advisory Business A. Description of the Advisory Firm Legacy Capital Wealth Partners, LLC (“Legacy Capital” or the “Advisor”) is a limited liability company organized in the State of Delaware. Legacy Capital became an investment advisory firm registered with the United States Securities and Exchange Commission (“SEC”) in February 2018. Legacy Capital is owned by Legacy Capital Wealth Holdings, LLC. The majority owners of Legacy Capital Wealth Holdings, LLC are Matthew Jones and Jason Prather. If you have any questions regarding the contents of this Disclosure Brochure, please do not hesitate to contact the Advisor’s Chief Compliance Officer, Keith Krueger by telephone at (501) 376-7878 or by email at keithk@legacycapitalwp.com. B. Types of Advisory Services Legacy Capital provides holistic and personalized financial planning and discretionary and non- discretionary investment advisory services to individuals, high net worth individuals, families, family offices, trusts, estates, businesses, charitable foundations, nonprofit organizations and retirement/profit-sharing plans (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Legacy Capital’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Financial Planning and Consulting Services Legacy Capital offers financial planning and consulting services to Clients. Such engagements may be part of the investment advisory engagement or pursuant to a separate engagement. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including, but not limited to: cash flow analysis, investment planning, retirement planning, estate planning, personal savings, educational savings, and other areas of a Client’s financial situation. Clients are encouraged, but are not required, to engage Legacy Capital for financial planning or consulting services. A financial plan developed for or financial consultation rendered to the Client will typically include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment 4  Legacy Capital Wealth Partners, LLC Disclosure Brochure programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Legacy Capital may recommend the services of itself and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if Legacy Capital recommends its own services, as such a recommendation may increase the advisory fees paid to Legacy Capital. The Client is under no obligation to act upon any of the recommendations made by Legacy Capital under a financial planning or consulting engagement to engage the services of any such recommended professional, including Legacy Capital itself. Investment Management Services Legacy Capital focuses on providing objective and holistic advice to Clients. In designing and implementing customized portfolio strategies, Legacy Capital can manage, on a discretionary or non-discretionary basis, a broad range of investment strategies and vehicles. Legacy Capital primarily allocates Client assets among various mutual funds, exchange-traded funds (“ETFs”), alternative investments, options, and individual debt and equity securities in accordance with the Client’s stated investment objectives. Legacy Capital may further recommend to Clients that all or a portion of their investment portfolio be managed on a discretionary basis by one or more unaffiliated money managers or investment platforms (“External Managers”). The Client may be required to enter into a separate agreement with the External Manager[s], which will set forth the terms and conditions of the Client’s engagement of the External Manager, or will receive a Statement of Investment Selection in a single contract relationship. Legacy Capital generally renders services to the Client relative to the discretionary selection of External Manager[s]. Legacy Capital also assists in establishing the Client’s investment objectives for the assets managed by External Manager[s], monitors and reviews the account performance and defines any restrictions on the account. The investment management fees charged by the designated External Manager[s], together with the fees charged by the corresponding designated broker-dealer/custodian of the Client’s assets, may be exclusive of, and in addition to, the annual advisory fee charged by Legacy Capital. Comprehensive Management Services Based on the needs and objectives of the Client, Legacy may provide additional services and work closely with their respective accountant, attorney or another specialist, as appropriate to manage their unique situation, as needed, pursuant to the investment management agreement. Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to 5  Legacy Capital Wealth Partners, LLC Disclosure Brochure roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g., commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Retirement Plan Advisory Services Legacy Capital provides 3(21) retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: • Vendor Analysis • Plan Participant Enrollment and Education Tracking • Investment Policy Statement (“IPS”) Design and Monitoring • Investment Management • Performance Reporting • Ongoing Investment Recommendation and Assistance • ERISA 404(c) Assistance • Benchmarking Services These services are provided by Legacy Capital serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Legacy Capital’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client-Tailored Advisory Services Legacy Capital seeks to provide personalized, tailored advisory services designed to meet the specific needs of each Client. Legacy Capital works collaboratively with its Clients, and any of its Clients’ outside advisors, including lawyers, accountants, and tax advisors, to meet its Clients’ goals. Client portfolios are managed on the basis of individual Clients’ financial situation and investment objectives. Clients may impose reasonable restrictions on the management of their accounts if Legacy Capital determines, in its sole discretion, that the conditions would not materially impact the performance of a management strategy or prove overly burdensome for Legacy Capital’s management efforts. 6  Legacy Capital Wealth Partners, LLC Disclosure Brochure D. Wrap Fee Programs For certain client relationships, Legacy includes securities transaction fees, custodial costs, administrative fees, wire fees, trade away transactions, other fees and expenses (herein “Covered Costs) together with its investment advisory fees. Including these fees into a single asset-based fee is considered a “Wrap Fee Program”. The Advisor customizes its investment management services for its Clients. The Advisor sponsors the Legacy Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees. Depending on the level of trading required for the Client’s account[s] in a particular year, the Client may pay more or less in total fees than if the Client paid its own transaction fees. Please see Appendix 1 – Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure. E. Assets Under Management As of December 31, 2024, Legacy Capital manages approximately $1,317,812,779 in Client assets, of which $1,077,426,065 are managed on a discretionary basis and $240,386,714 on a non- discretionary basis. Item 5 - Fees and Compensation A. Fee Schedule for Advisory Services Investment Management Services Legacy Capital charges an annual advisory fee that is agreed upon with each Client and set forth in an agreement executed by Legacy Capital and the Client. Legacy Capital and any Client may, however, agree to adjust the fee annually or on a more frequent basis. Legacy Capital’s fee for investment advisory services is negotiable and varies based on a multitude of factors, including, but not limited to, the size of the relationship and the nature and complexity of the products and investments involved, service intensity, degree of custom work, time requirement, number of entities, number of family members served and travel requirements. The fee can be based on a percentage of assets under management or a fixed dollar amount. If based on a percentage of the value of assets under management, the fee generally ranges between 0.50% and 1.50% annually of the Client’s net billable assets under management. If based on a percentage of the value of assets under management, the initial advisory fee for the first calendar quarter (or part thereof) in which the Client enters into an advisory agreement with Legacy Capital shall be calculated on the day after initial assets are placed with Legacy Capital and shall be the advisory fee for the first calendar quarter (or part thereof). The initial advisory fee for any partial quarter is payable on a pro rata basis based on the number of calendar days in the partial quarter and is paid in the month following the establishment of the Client account. For subsequent quarters, the advisory fee generally is payable in advance (except for services to participant-directed 401k plans, 7  Legacy Capital Wealth Partners, LLC Disclosure Brochure which are payable either in advance or arrears, depending on the terms of the agreement), based on the market value of assets under management on the last business day of the prior calendar quarter. If a fixed dollar amount, the advisory fee for the initial quarter is payable, on a pro rata basis, in arrears. For subsequent quarters, the fixed fee generally is payable in advance. All securities held in accounts managed by Legacy Capital will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Legacy Capital generally requires a minimum balance of assets under management per household of $500,000; this requirement may be waived solely in the discretion of the Advisor. Financial Planning Services Legacy Capital offers its Clients financial planning services for a fixed fee. Clients enter into a separate agreement with Legacy Capital for financial planning services. The standard fee for such services ranges from $2,500 to $10,000; the actual fee charged varies, based upon amount, type and nature of the Client’s assets and liabilities involved, the number of family members, travel commitments scope of work, and specific requests made by the Client. The Client is required to pay one-half of the fee up-front prior to the commencement of work on the financial plan; the remainder is due after the financial plan is completed. Legacy Capital generally waives the remaining fee if the Client enters into an advisory relationship with the Advisor. Legacy Capital reserves the right to charge a financial planning fee greater than $10,000 based on factors that include, but are not limited to, the amount, type and nature of the Client’s assets and liabilities involved, the number of family members, travel commitments scope of work, and specific requests made by the Client. For any services that will be completed six (6) months or more in advance, Legacy Capital will only collect advance fees of up to $1,200. Legacy Capital also offers its Clients consulting services on a flat fee basis negotiated by Legacy Capital and the Client. The fee varies depending on the services provided and the experience, knowledge, and skill of those performing the services on behalf of Legacy Capital. The scope and charges of all work must be agreed-upon in writing by Legacy Capital and the Client before any billing begins. 8  Legacy Capital Wealth Partners, LLC Disclosure Brochure Retirement Plan Advisory Services Fees for retirement plan advisory services are charged an annual asset-based fee of up to 1.50% and are billed quarterly, and may be billed in advance or arrears (the “Billing Period”), pursuant to the terms of the retirement plan advisory agreement. Retirement plan fees are based on the market value of assets under management at the end of the respective Billing Period. Fees may be negotiable depending on the size and complexity of the Plan. B. Payment of Fees Investment Management Services Legacy Capital generally deducts its advisory fee from a Client’s investment account[s] held at the custodian. Upon engaging Legacy Capital to manage such account[s], a Client grants Legacy Capital this limited authority through a written instruction to the custodian of the Client’s account[s]. The Client is responsible to verify the accuracy of the calculation of the advisory fee; the custodian will not determine whether the fee is accurate or properly calculated. The fee generally is billed on a quarterly basis in advance of each calendar quarter, except the services to participant-directed 401k plans that are billed either in advance or in arrears depending on the terms of the agreement. A Client may utilize the same procedure for financial planning or consulting fees in arrears or in advance if the Client has investment accounts held at a custodian. Although Clients generally are required to have their investment advisory fees deducted from their accounts, in some cases, Legacy Capital will directly bill a Client for investment advisory fees if it determines that such billing arrangement is appropriate given the circumstances. The custodian of the Client’s account[s] provides each Client with a statement, at least quarterly, indicating separate line items for all amounts disbursed from the Client's account[s], including any fees paid directly to Legacy Capital. Clients may make additions to and withdrawals from their account at any time, subject to Legacy Capital’s right to terminate an account. Additions may be in cash or securities provided that the Advisor reserves the right to liquidate transferred securities or decline to accept particular securities into a Client’s account. Clients may withdraw account assets at any time on notice to Legacy Capital, subject to the usual and customary securities settlement procedures. However, the Advisor generally designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a Client’s investment objectives. Legacy Capital may consult with its Clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g. contingent deferred sales charges) and/or tax ramifications. 9  Legacy Capital Wealth Partners, LLC Disclosure Brochure Financial Planning Services Financial planning fees may be invoiced up to fifty percent (50%) of the expected total fee upon execution of the financial planning agreement. The balance shall be invoiced upon completion of the agreed upon deliverable[s]. Retirement Plan Advisory Services Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. C. Other Fees and Expenses For assets in the Legacy Wrap Fee Program, Clients may incur certain fees or charges imposed by third parties in connection with investments made on behalf of the Client’s account[s]. Legacy includes Covered Costs as part of its overall investment advisory fee through the Legacy Wrap Fee Program. Securities transaction fees for Client-directed trades may be charged back to the Client. Please see Item 4.D. above as well as Appendix 1 – Wrap Fee Program Brochure. For assets not in the Legacy Wrap Fee Program, in addition to Legacy Capital’s advisory fee, Clients will be responsible for the fees and expenses of the custodian[s], underlying mutual funds, External Managers and their platform manager (if any), transfer taxes, odd lot differentials, exchange fees, interest charges, ADR processing fees, and any charges, taxes or other fees mandated by any federal, state or other applicable law, retirement plan account fees (where applicable), electronic fund and wire fees. Clients should review the applicable prospectuses for additional information about fund fees and expenses. Legacy Capital’s recommended Custodian does not charge securities transaction fees for ETF and equity trades in Client’s accounts, provided that the account meets the terms and conditions of the Custodian’s brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. For External Managers, Clients should review each manager’s Form ADV 2A disclosure brochure and either the contract they sign with the External Manager (in a dual contract relationship) or their Statement of Investment Selection (in a single contract relationship) for additional information about fees and expenses charged. D. Prepayment of Fees Investment Management Services As noted in Item 5(B) above, Legacy Capital’s advisory fees generally are paid in advance. Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five- 10  Legacy Capital Wealth Partners, LLC Disclosure Brochure day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. The Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Upon the termination of a Client’s advisory relationship, Legacy Capital will issue a refund equal to any unearned management fee for the remainder of the quarter. The Client may specify how he/she would like such refund issued (i.e., a check sent directly to the Client or a check sent to the Client’s custodian for deposit into his/her account). Financial Planning Services Legacy Capital requires an advance deposit as described above. Either party may terminate the financial planning agreement by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for the percentage of the engagement scope completed by the Advisor. The Advisor will refund any unearned, prepaid planning fees from the effective date of termination. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. Retirement Plan Advisory Services Legacy Capital is compensated for its services at the beginning or the end of the quarter in which retirement plan advisory services are rendered. Either party may terminate the retirement plan advisory agreement, at any time, by providing advance written notice to the other party. Upon termination, the Client shall be responsible for investment advisory fees up to and including the effective date of termination. The Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The Client’s retirement plan advisory agreement with the Advisor is non-transferable without the Client’s prior consent. E. Outside Compensation for Sale of Securities or Other Investment Products to Clients Legacy Capital does not buy or sell securities and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Certain representatives who provide investment advice to Clients (our “Advisory Persons”) may also be registered representatives of Purshe Kaplan Sterling Investments, Inc. (“PKS”) a FINRA- registered broker-dealer and member of SIPC. 11  Legacy Capital Wealth Partners, LLC Disclosure Brochure An Advisory Person who is a registered representative of PKS will implement securities transactions on a commission basis through PKS. In such instances, the Advisory Person will receive commission-based compensation in connection with the purchase and sale of securities, as well as a share of any ongoing distribution or service (trail) fees, including 12b-1 fees for the sale of investment company products. Compensation earned by the Advisory Person in his or her capacity as a registered representative is separate from and in addition to Legacy Capital’s advisory fee. The receipt of such compensation by an Advisory Person presents a conflict of interest as an Advisory Person who is a registered representative may have an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on Client needs. To mitigate these conflicts, Clients are under no obligation to purchase securities products through PKS or Advisory Persons who are registered representatives or otherwise engage such persons and may choose brokers or agents not affiliated with Legacy Capital or PKS. Further, Legacy Capital will not charge an ongoing investment advisory fee on assets purchased by a Client through an Advisory Person acting in their capacity as a registered representative. Certain Advisory Persons of Legacy Capital are also be licensed as insurance professionals through Legacy Capital Group Arkansas, LLC. Such persons earn commission-based compensation for selling insurance products to Clients. Insurance commissions earned by Advisory Persons who are insurance professionals are separate from and in addition to Legacy Capital’s advisory fee. This practice presents a conflict of interest as an Advisory Person who is an insurance professional may have an incentive to recommend insurance products for the purpose of generating commissions rather than solely based on Client needs. Clients are under no obligation to purchase insurance products through any person affiliated with Legacy Capital. Item 6 - Performance-Based Fees and Side-by-Side Management Legacy Capital does not charge performance-based fees or participate in side-by-side management. Performance-based fees are fees that are based on a share of a capital gains or capital appreciation of a Client’s account. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. Legacy Capital’s fees are calculated as described in Item 5 above. Item 7 - Types of Clients Legacy Capital offers personalized investment advisory services to individuals, high net worth individuals, families, family offices, trusts, businesses, charitable foundations, nonprofit organizations and retirement/profit-sharing plans. Legacy Capital generally requires a minimum balance of assets under management per household of $500,000; this requirement may be waived solely in the discretion of the Advisor. 12  Legacy Capital Wealth Partners, LLC Disclosure Brochure Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis and Risk of Loss A primary step in Legacy Capital’s investment strategy is getting to know the Clients – to understand the Client’s financial condition, risk profile, investment goals, tax situation, liquidity constraints – and assemble a complete picture of their financial situation. To aid in this understanding, Legacy Capital offers Clients financial planning services to its Clients that is highly customized and tailored. This comprehensive, holistic approach is integral to the way that Legacy Capital does business. Once Legacy Capital has a true understanding of its Clients’ needs and goals, the investment process can begin, and the Advisor can recommend strategies and investments that it believes are aligned with the Client’s goals and risk profile. Legacy Capital primarily employs fundamental analysis in developing investment strategies for its Clients. Research and analysis from Legacy Capital is based on numerous sources, including third- party research materials and publicly-available materials, such as company annual reports, prospectuses, and press releases. Legacy Capital generally employs a long-term investment strategy for its Clients, if consistent with their financial goals. Legacy Capital will typically hold all or a portion of a securities position for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, the Advisor may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. Client portfolios with similar investment objectives and asset allocation goals may own different securities and investments. The Client’s portfolio size, tax sensitivity, desire for simplicity, income needs, long-term wealth transfer objectives, time horizon and choice of custodian are all factors that influence Legacy Capital’s investment recommendations. Investing in securities involves a risk of loss. A Client can lose all or a substantial portion of his/her investment. A Client should be willing to bear such a loss. Some investments are intended only for sophisticated investors and can involve a high degree of risk. B. Material Risks Involved All investments and investment programs have a variety of risks that are borne by the investor. As such, there can be no assurance that any investment strategy will prove profitable or successful. A Client can lose all or a substantial portion of his/her investment. A Client should be willing to bear such a loss. Some investments are intended only for sophisticated investors and can involve a high degree of risk. 13  Legacy Capital Wealth Partners, LLC Disclosure Brochure The following risks could cause equities, fixed-income securities, mutual funds, ETFs, alternative investments, and other investments in Client portfolios to decrease in value: • Market Risk: The price of an equity security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, changes in political, economic and social conditions may trigger adverse market events. • ETF Risk: The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. • Mutual Fund Risk: The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • Event Risk: An adverse event affecting a particular company or that company’s industry could depress the price of a Client’s investments in that company’s stocks or bonds. The company, government or other entity that issued bonds in a Client’s portfolio could become less able to, or fail to, repay, service or refinance its debts, or the issuer’s credit rating could be downgraded by a rating agency. Adverse events affecting a country, including political and economic instability, could depress the value of investments in issuers headquartered or doing business in that country. • Liquidity Risk: Securities that are normally liquid may become difficult or impossible to sell at an acceptable price during periods of economic instability or other emergency conditions. Some securities may be infrequently or thinly traded even under normal market conditions. 14  Legacy Capital Wealth Partners, LLC Disclosure Brochure • Leverage Risk: The use of leverage may lead to increased volatility of a fund’s NAV and market price relative to its common shares. Leverage is likely to magnify any losses in the trust/fund’s portfolio, which may lead to increased market price declines. Fluctuations in interest rates on borrowings or the dividend rates on preferred shares that take place from changes in short- term interest rates may reduce the return to common shareholders or result in fluctuations in the dividends paid on common shares. There is no assurance that a leveraging strategy will be successful. • Domestic and/or Foreign Political Risk: The events that occur in the U.S. relating to politics, government, and elections can affect the U.S. markets. Political events occurring in the home country of a foreign company such as revolutions, nationalization, and currency collapse can have an impact on the security. • Inflation Risk: Countries around the globe may be more, or less, prone to inflation than the U.S. economy at any given time. Companies operating in countries with higher inflation rates may find it more difficult to post profits reflecting its underlying health. • Currency Risk: Overseas investments are subject to fluctuations in the value of the U.S. dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This risk is that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. • Operational Risk: Fund Advisors and other ETF service providers may experience disruptions or operating errors such as processing errors or human errors, inadequate or failed internal or external processes, or systems or technology failures, that could negatively impact the ETF. • Regulatory/Legislative Developments Risk: Regulators and/or legislators may promulgate rules or pass legislation that places restrictions on, adds procedural hurdles to, affects the liquidity of, and/or alters the risks associated with certain investment transactions or the securities underlying such investment transactions. Such rules/legislation could affect the value associated with such investment transactions or underlying securities • Illiquid Securities: Investments in hedge funds and other private investment funds may underperform publicly offered and traded securities because such investments: o Typically require investors to lock‐up their assets for a period and may be unable to meet redemption requests during adverse economic conditions; 15  Legacy Capital Wealth Partners, LLC Disclosure Brochure o Have limited or no liquidity because of restrictions on the transfer of, and the absence of a market for, interests in these funds; o Are more difficult to monitor and value due to a lack of transparency and publicly available information about these funds; o May have higher expense ratios and involve more inherent conflicts of interest than publicly traded investments; and o Involve different risks than investing in registered funds and other publicly offered and traded securities. These risks may include those associated with more concentrated, less diversified investment portfolios, investment leverage and investments in less liquid and non‐traditional asset classes. Past performance of a security or a fund is not necessarily indicative of future performance or risk of loss. Use of Mutual Funds and ETFs: The risk of ownership of fund shares generally depends on the asset class and number of securities held by the fund. Funds generally own securities and therefore also involve the risk of loss that is inherent in investing in securities. The risks also may be significantly increased if a mutual fund pursues an alternative investment strategy, which may involve special risks associated with short sales, leveraging the investment, potential adverse market forces, regulatory changes, and potential illiquidity. Investing in alternative strategies presents the opportunity for significant losses. Returns on mutual fund investments are reduced by management costs and expenses. Mutual funds also are subject to the individual risks described in their prospectus. An ETF’s risks include declining value of the securities held by the ETF, adverse developments in the specific industry or sector that the ETF tracks, capital loss in geographically focused funds because of unfavorable fluctuation in currency exchange rates, differences in generally accepted accounting principles, economic or political instability, tracking errors (the difference between the return of the ETF and the return of its benchmark), and trading at a premium or discount, meaning the difference between the ETF’s market price and net asset value (“NAV”). ETFs also are subject to the individual risks described in their prospectus. Although the goal of diversification is to combine investments with different characteristics so that the risks inherent in any one investment can be balanced by assets that move in different cycles or respond to different market factors, diversification does not eliminate the risk of loss. In some circumstances, price movements may be highly correlated across securities and funds. A specific 16  Legacy Capital Wealth Partners, LLC Disclosure Brochure fund may not be diversified and a Client portfolio may not be diversified. Additionally, when diversification is a Client objective, there is risk that the strategies that the Advisor uses may not be successful in achieving the desired level of diversification. There is also risk that the strategies, resources, and analytical methods that the Advisor uses to identify mutual funds and ETFs will not be successful in identifying investment opportunities. Use of Independent Managers Legacy Capital may select certain External Manager[s] to manage a portion of its Clients’ assets. In these situations, Legacy Capital conducts due diligence of such managers, but the success of such recommendations relies to a great extent on the External Managers’ ability to successfully implement their investment strategies. Legacy Capital generally does not have the ability to supervise the External Managers on a day-to-day basis. Legacy Capital does not perform independent due diligence on the External Managers it recommends for Client accounts; rather, it relies on the due diligence on such managers performed by platform managers. Item 9 – Disciplinary Information Registered investment advisors are required to disclose all material facts regarding any legal or disciplinary events that would be material to a Client’s evaluation of Legacy Capital and the integrity of Legacy Capital’s management. Legacy Capital has no information applicable to this Item. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor and its Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 291960. Item 10 – Other Financial Industry Activities and Affiliations Registrations with Broker-Dealer As detailed in Item 5, certain Advisory Persons providing investment advice on behalf of Legacy Capital are registered representatives with PKS, a securities broker-dealer, and a member of FINRA and SIPC. In such instances, the Advisory Person will receive commission-based compensation in connection with the purchase and sale of securities, as well as a share of any ongoing distribution or service (trail) fees, including 12b-1 fees for the sale of investment company products. Compensation earned by the Advisory Person in his or her capacity as a registered representative is separate from and in addition to Legacy Capital’s advisory fee. The receipt of such compensation by an Advisory Person presents a conflict of interest as an Advisory Person who is a registered representative may have an incentive to effect securities transactions for the 17  Legacy Capital Wealth Partners, LLC Disclosure Brochure purpose of generating commissions rather than solely based on Client needs. To mitigate these conflicts, Clients are under no obligation to purchase securities products through PKS or Advisory Persons who are registered representatives or otherwise engage such persons and may choose brokers or agents not affiliated with Legacy Capital or PKS. Recommendation of External Managers Legacy Capital may recommend that Clients use External Managers based on the Client’s needs and suitability. Legacy Capital does not receive separate compensation, directly or indirectly, from such external managers for recommending that Clients use their services. Legacy Capital does not have any other business relationships with the recommended External Managers. Licensed Insurance Agents As detailed in 5, certain Advisory Persons are licensed insurance agents with Legacy Capital Group Arkansas, LLC, an affiliate of Legacy Capital, and offer certain insurance products on a fully-disclosed commissionable basis. A conflict of interest exists to the extent that Legacy Capital recommends the purchase of insurance products where its Advisory Persons may be entitled to insurance commissions or other additional compensation. Clients are under no obligation to purchase insurance products through any person affiliated with Legacy Capital. The Advisor has procedures in place whereby it seeks to ensure that all recommendations are made in its Clients’ best interest regardless of any such affiliations. Comprehensive Services As a part of Legacy’s Comprehensive Services which includes direct interaction and coordination with third parties including, but not limited to, the clients’ accountant and attorney, the fees charged by these third parties will be paid by the Advisor to the third parties from Advisory fees paid to the Advisor pursuant to the Investment Management Agreement. Item 11 – Code of Ethics, Participation or Interest in Client Transactions A. Description of Code of Ethics Legacy Capital has a Code of Ethics (the “Code”) which requires Legacy Capital’s employees (“Supervised Persons”) to comply with their legal obligations and fulfill the fiduciary duties owed to the Advisor’s Clients. Among other things, the Code of Ethics sets forth policies and procedures related to conflicts of interest, outside business activities, gifts and entertainment, compliance with insider trading laws and policies and procedures governing personal securities trading by Supervised Persons. 18  Legacy Capital Wealth Partners, LLC Disclosure Brochure Personal securities transactions of Supervised Persons present conflicts of interest with the price obtained in Client securities transactions or the investment opportunity available to Clients. The Code addresses these conflicts by prohibiting securities trades that would breach a fiduciary duty to a Client and requiring, with certain exceptions, Supervised Persons to report their personal securities holdings and transactions to Legacy Capital for review by the Advisor’s Chief Compliance Officer. The Code also requires Supervised Persons to obtain pre-approval of certain investments, including initial public offerings and limited offerings. Legacy Capital will provide a copy of the Code of Ethics to any Client or prospective Client upon request. Item 12 – Brokerage Practices A. Factors Used to Select Custodians and/or Broker-Dealers Client assets must be maintained in an account at a “Qualified Custodian.” Legacy Capital generally recommends that its investment management Clients utilize the custody and brokerage services of an unaffiliated broker-dealer custodian as its broker-dealer/custodian (herein collectively the “Custodian”) with which Legacy Capital has an institutional relationship. Currently, this includes Schwab Advisor Services, a division of Charles Schwab & Co., Inc. (“Schwab”) and Fidelity Clearing & Custody Solutions, and related entities of Fidelity Investments, Inc. (collectively “Fidelity”), which both are a “Qualified Custodian” as that term is described in Rule 206(4)-2 of the Investment Advisers Act of 1940. Each Custodian provides custody of securities, trade execution, and clearance and settlement of transactions placed by Legacy Capital. If your accounts are custodied at Schwab of Fidelity, they will hold your assets in a brokerage account and buy and sell securities when we instruct them to. While Legacy Capital recommends that Clients use Schwab or Fidelity as Custodian, Clients decide whether to do so and open accounts with Schwab or Fidelity by entering into an account agreement directly with Schwab or Fidelity. Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by Legacy Capital. In deciding to recommend Schwab and Fidelity, some of the factors that Legacy Capital considers include: • combination of transaction execution services along with asset custody service; • order execution and the ability to provide accurate and timely execution, clearing and settlement of trades; • capabilities to facilitate transfers and payments to and from accounts; • the reasonableness and competitiveness of services, including commission rates and other fees and transaction costs; • access to a broad range of investment products, including stocks, bonds, mutual funds, and exchange-traded funds; 19  Legacy Capital Wealth Partners, LLC Disclosure Brochure • availability of investment research and tools that assist the Advisor in making investment decisions; • quality of services; • access to trading desks; • technology that integrates within Legacy Capital’s environment, including interfacing with Legacy Capital’s portfolio management system; • a dedicated service or back-office team and its ability to process requests from Legacy Capital on behalf of its Clients; • ability to provide Legacy Capital with access to Client account information through an institutional website; • ability to provide Clients with electronic access to account information and • investment and research tools; and reputation, financial strength, and stability. Legacy Capital may place portfolio transactions through the Custodian where the Clients’ accounts are custodied. In exchange for using the services of the Custodian, Legacy Capital may receive, without cost, computer software and related systems support that allows Legacy Capital to monitor and service its Clients’ accounts maintained with such Custodian. Both Custodians also makes available to the Advisor products and services that benefit the Advisor but may not directly benefit the Client or the Client’s account. These products and services assist the Advisor in managing and administering Client accounts. They include investment research, both the Custodians own and that of third parties. Legacy Capital may use this research to service all or some substantial number of Client accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab and Fidelity also makes available software and other technology that: • provide access to Client account data (such as duplicate trade confirmations and • account statements); facilitate trade execution and allocate aggregated trade orders for multiple Client accounts; facilitate payment of our fees from our Clients’ accounts; and • provide pricing and other market data; • • assist with back-office functions, recordkeeping, and Client reporting. The Custodians also offer other services intended to help the Advisor manage and further develop our business enterprise. These services include: • educational conferences and events; • technology, compliance, legal, and business consulting; 20  Legacy Capital Wealth Partners, LLC Disclosure Brochure • publications and conferences on practice management and business succession; and • access to employee benefits providers, human capital consultants, and insurance providers. The Custodians may provide some of these services itself. In other cases, it will arrange for third- party vendors to provide the services to the Advisor. The Custodians may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. The Custodians may also provide the Advisor with other benefits such as occasional business entertainment of the Advisor’s personnel. Legacy Capital will periodically review its arrangements with the Custodians and other broker- dealers against other possible arrangements in the marketplace as it strives to achieve best execution on behalf of its Clients. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including, but not limited to, the following: • a broker-dealer’s trading expertise, including its ability to complete trades, execute and settle difficult trades, obtain liquidity to minimize market impact and accommodate unusual market conditions, maintain anonymity, and account for its trade errors and correct them in a satisfactory manner; • a broker-dealer’s infrastructure, including order-entry systems, adequate lines of communication, timely order execution reports, an efficient and accurate clearance and settlement process, and capacity to accommodate unusual trading volume; • a broker-dealer’s ability to minimize total trading costs while maintaining its financial health, such as whether a broker-dealer can maintain and commit adequate capital when necessary to complete trades, respond during volatile market periods, and minimize the number of incomplete trades; • a broker-dealer’s ability to provide research and execution services, including advice as to the value or advisability of investing in or selling securities, analyses and reports concerning such matters as companies, industries, economic trends and political factors, or services incidental to executing securities trades, including clearance, settlement and custody; and • a broker-dealer’s ability to provide services to accommodate special transaction needs, such as the broker-dealer’s ability to execute and account for Client-directed arrangements and soft dollar arrangements, participate in underwriting syndicates, and obtain initial public offering shares. As described above, the Custodians provides to Legacy Capital, without cost, research and trade execution services. Schwab makes these services available to similarly situated investment 21  Legacy Capital Wealth Partners, LLC Disclosure Brochure advisers whose Clients custody their assets with Schwab. Access to research and trade execution services is not predicated on the execution of Client securities transactions (e.g., not “soft dollars.”) Legacy Capital has not entered into any formal “soft dollar” arrangements with broker-dealers. Legacy Capital’s Clients may utilize qualified custodians other than Schwab or Fidelity for certain accounts and assets, particularly where Clients have a previous relationship with such qualified custodians. Brokerage for Client Referrals Legacy Capital does not select or recommend broker-dealers based solely on whether or not it may receive Client referrals from a broker-dealer or third party. Client-Directed Brokerage Generally, in the absence of specific instructions to the contrary, for brokerage accounts that Clients engage Legacy Capital to manage on a discretionary basis, Legacy Capital has full discretion with respect to securities transactions placed in the accounts. This discretion includes the authority, without prior notice to the Client, to buy and sell securities for the Client’s account and establish and affect securities transactions through the Custodian of the Client’s account or other broker-dealers selected by Legacy Capital. In selecting a broker-dealer to execute a Client’s securities transactions, Legacy Capital seeks prompt execution of orders at favorable prices. Legacy Capital does not permit Clients to direct some or all of their brokerage transactions to a specific broker-dealer. In addition to accounts managed by Legacy Capital on a discretionary basis where the Client has directed the brokerage of his/her account[s], certain institutional accounts may be managed by Legacy Capital on a non-discretionary basis and are held at custodians selected by the institutional Client. The decision to use a particular custodian and/or broker-dealer generally resides with the institutional Client. Legacy Capital endeavors to understand the trading and execution capabilities of any such custodian and/or broker-dealer, as well as its costs and fees. Legacy Capital may assist the institutional Client in facilitating trading and other instructions to the custodian and/or broker- dealer in carrying out Legacy Capital’s investment recommendations. Trade Errors Legacy Capital’s goal is to execute trades seamlessly and in the best interests of the Client. In the event a trade error occurs, Legacy Capital endeavors to identify the error in a timely manner, correct the error so that the Client’s account is in the position it would have been had the error not 22  Legacy Capital Wealth Partners, LLC Disclosure Brochure occurred, and, after evaluating the error, assess what action[s] might be necessary to prevent a recurrence of similar errors in the future. Trade errors generally are corrected through the use of a “trade error” account or similar account at Schwab, or another broker-dealer, as the case may be. In the event an error is made in a Client account custodied elsewhere, Legacy Capital works directly with the broker in question to take corrective action. In all cases, Legacy Capital will take the appropriate measures to return the Client’s account to its intended position. B. Trade Aggregation To the extent that the Advisor determines to aggregate Client orders for the purchase or sale of securities, including securities in which the Advisor’s Supervised Persons may invest, the Advisor will generally do so in a fair equitable manner in accordance with applicable rules promulgated under the Advisers Act and guidance provided by the staff of the SEC and consistent with policies and procedures established by the Advisor. Item 13 – Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews Legacy Capital monitors investment advisory portfolios as part of a continuous and ongoing process. Legacy Capital advisors have at least one annual meeting with each Client to conduct a formal review of the Clients’ account. These reviews may include the following: review holdings and consider alternatives; • compare the account’s allocation with stated goals and Client cash-flows at time of review; • • monitor the size of individual securities relevant to their sectors, asset classes, and overall account size; • analyze an account’s composition and performance, income, appreciation, gains/losses, and asset allocation; and • assess its performance. Factors that may trigger an additional review, other than a periodic review, include: material market, economic or political events, known significant changes in a Client’s financial situation and/or objectives, and large deposits or withdrawals form the accounts. Clients are encouraged to notify Legacy Capital if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. 23  Legacy Capital Wealth Partners, LLC Disclosure Brochure B. Other Reviews Legacy Capital may perform compliance and/or supervisory reviews of a sampling of Client accounts. These reviews may include comparing an account’s strategy and/or allocation to the account’s stated objectives, reviewing commission and transaction costs borne by the account, and reviewing the billing rate and charges. C. Content and Frequency of Regular Reports Provided to Clients Legacy Capital intends to provide quarterly performance reports to Clients within 30 days of the end of each calendar quarter. Additionally, Legacy Capital offers its Clients access to an online reporting platform that updates performance and holdings daily. Clients will also receive brokerage statements no less than quarterly from the qualified custodian. These brokerage statements are sent directly from the custodian to the Client. The Client may also establish electronic access to the custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Client advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients Participation in Institutional Advisor Platform Legacy Capital has engaged two qualified custodians and will generally recommend that portfolio management Clients establish accounts with either Schwab through its “Schwab Advisor Services” unit or Fidelity Clearing & Custody Solutions, and related entities of Fidelity Investments, Inc. (collectively “Fidelity”), both registered broker-dealers, member SIPC, to maintain custody of Clients’ assets and to effect trades for their accounts. Fidelity Legacy Capital maintains an institutional relationship with Fidelity Clearing & Custody Solutions, and related entities of Fidelity Investments, Inc. (collectively “Fidelity”) whereby Legacy Capital receives certain benefits. Legacy Capital may receive from Fidelity, without cost to Legacy Capital, computer software and related systems support, which allow Legacy Capital to better monitor Client accounts maintained at Fidelity, facilitate trade execution (and allocation of aggregated trade orders for multiple Client accounts), provide research, pricing information and other market data and assist with back-office functions, recordkeeping and Client reporting. Legacy Capital may receive the software and related support without cost because Legacy Capital renders investment management services to Clients that maintain assets at Fidelity. 24  Legacy Capital Wealth Partners, LLC Disclosure Brochure Specifically, Legacy Capital may receive the following benefits from Fidelity: receipt of duplicate Client confirmations and bundled duplicate statements, access to a trading desk that exclusively services its Registered Investment Adviser Group participants and access to an electronic communication network for Client account information. In addition, Fidelity also makes available to Legacy Capital other services intended to help Legacy Capital manage and further develop its business enterprise. These services may include publications and conferences on practice management, information technology and regulatory compliance. Legacy Capital is independently owned and operated and not affiliated with Fidelity. Fidelity provides Legacy Capital with access to its institutional trading and custody services, which are typically not available to Fidelity retail investors. These services are generally available to independent investment advisors on an unsolicited basis and are not otherwise contingent upon Legacy Capital committing to Fidelity any specific amount of business (assets in custody or trading). For Legacy Capital’s Client accounts maintained there, Fidelity is compensated through commissions or other transaction-related fees for securities trades that are executed through Fidelity or that settle into Fidelity accounts. The brokerage commissions and/or transaction fees charged by Fidelity or any other designated broker-dealer are exclusive of and in addition to Legacy Capital’s fees. Any commissions paid by Legacy Capital’s Clients shall comply with Legacy Capital’s duty to obtain “best execution.” However, a Client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction where Legacy Capital determines, in good faith, that the commission is reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including among others, the value of research provided, execution capability, commission rates, and responsiveness. Consistent with the foregoing, while Legacy Capital will seek competitive rates, it may not necessarily obtain the lowest possible commission rates for Client transactions. Charles Schwab Advisor Services As a registered investment advisor participating on the Schwab Advisor Services platform, Legacy Capital receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a conflict of interest since these benefits may influence the 25  Legacy Capital Wealth Partners, LLC Disclosure Brochure Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services and financial support to Legacy Capital that may not benefit the Client, including: educational conferences and events, financial start-up support, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a conflict of interest. Legacy Capital believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. B. Compensation for Client Referrals Legacy Capital does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 15 – Custody Legacy Capital does not accept or maintain custody of Client accounts, except for the limited circumstances outlined below: Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction of advisory fees, all Clients for whom Legacy Capital exercises discretionary authority must hold their assets with a "qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and securities and must instruct Legacy Capital to utilize that Custodian for securities transactions on their behalf. Clients are encouraged to review 26  Legacy Capital Wealth Partners, LLC Disclosure Brochure statements provided by the Custodian and compare to any reports provided by Legacy Capital to ensure accuracy, as the Custodian does not perform this review. Money Movement Authorization - For instances where Clients authorize Legacy Capital to move funds between their accounts, Legacy Capital and the Custodian have implemented safeguards to ensure that all money movement activities are conducted strictly in accordance with the Client’s documented instructions. Item 16 – Investment Discretion Clients have the option of providing Legacy Capital with investment discretion on their behalf, pursuant to a grant of a limited power of attorney contained in Legacy Capital’s Client agreement. By granting Legacy Capital investment discretion, a Client authorizes Legacy Capital to direct securities transactions and determine which securities are bought and sold, the total amount to be bought and sold, and the costs at which the transactions will be effected. Clients may impose reasonable limitations in the form of specific constraints on any of these areas of discretion with the consent and written acknowledgement of Legacy Capital. See also Item 4.C., Client-Tailored Advisory Services. Item 17 – Voting Client Securities Legacy Capital does not accept the authority to and does not vote proxies on behalf of Clients. Clients retain the responsibility for receiving and voting proxies for all and any securities maintained in Client portfolios. Clients may direct proxies to Legacy Capital; however, Legacy Capital will take no action on voting proxies. Item 18 – Financial Information A. Balance Sheet Legacy Capital does not require prepayment of more than $1,200 in fees per Client, six months or more in advance, and therefore does not need to include a balance sheet with this Disclosure Brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Legacy Capital nor its management has any financial conditions that are reasonably likely to impair its ability to meet contractual commitments to Clients. C. Bankruptcy Petitions in Previous Years Legacy Capital has not been the subject of a bankruptcy petition. 27 

LEGACY CAPITAL WEALTH PARTNERS, LLC FORM ADV PART 2A – APPENDIX 1 (“WRAP FEE PROGRAM BROCHURE”) Effective: March 24, 2025 This Form ADV2A - Appendix 1 (“Wrap Fee Program Brochure”) provides information about the qualifications and business practices for Legacy Capital Wealth Partners, LLC (“Legacy Capital” or the “Advisor”) services when offering services pursuant to a wrap program. This Wrap Fee Program Brochure shall always be accompanied by the Legacy Capital Disclosure Brochure, which provides complete details on the business practices of the Advisor. If you did not receive the complete Legacy Capital Disclosure Brochure or you have any questions about the contents of this Wrap Fee Program Brochure or the Legacy Capital Disclosure Brochure, please contact the Advisor at (501) 376-7878. Legacy Capital is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Wrap Fee Program Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Wrap Fee Program Brochure provides information about Legacy Capital to assist you in determining whether to retain the Advisor. Additional information about Legacy Capital and its advisory persons are available on the SEC’s website at www.adviserinfo.sec.gov by searching the Advisor’s firm name or CRD# 291960. 1  Item 2 – Material Changes Form ADV 2A - Appendix 1 provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. In particular, this Wrap Fee Program Brochure discusses the Wrap Fee Program offered by the Advisor. Material Changes There have been no material changes to this Wrap Fee Program Brochure since the last filing and distribution to Clients. Future Changes From time to time, the Advisor may amend this Wrap Fee Program Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Wrap Fee Program Brochure (along with the complete Legacy Capital Disclosure Brochure) or a Summary of Material Changes shall be provided to you annually and if a material change occurs in the business practices of Legacy Capital. At any time, you may view this Wrap Fee Program Brochure and the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching for the Advisor’s firm name or CRD# 291960. You may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at (501) 376-7878. Item 3 – Table of Contents Item 2 – Material Changes ......................................................................................................................... 2 Item 3 – Table of Contents ........................................................................................................................ 2 Item 4 – Services Fees and Compensation .............................................................................................. 3 Item 5 – Account Requirements and Types of Clients .......................................................................... 5 Item 6 – Portfolio Manager Selection and Evaluation ........................................................................... 5 Item 7 – Client Information Provided to Portfolio Managers ............................................................... 9 Item 8 - Client Contact With Portfolio Managers…………………………………………………9 Item 9 – Additional Information ............................................................................................................... 9 2  Item 4 – Services Fees and Compensation A. Services Legacy Capital provides customized investment advisory services for its Clients. This Wrap Fee Program Brochure is provided as a supplement to the Legacy Capital Disclosure Brochure (Form ADV 2A). This Wrap Fee Program Brochure is provided along with the complete Disclosure Brochure to provide full details of the business practices and fees when selecting Legacy Capital as your investment advisor. As part of the investment advisory fees noted in Item 5 of the Disclosure Brochure, Legacy Capital includes securities transaction fees for certain mutual funds (herein “Covered Costs”) as part of the overall investment advisory fee. Securities regulations often refer to this combined fee structure as a “Wrap Fee Program”. The Advisor’s recommended Custodians do not charge securities transaction fees for exchange-traded fund (“ETF”) and equity trades in Client accounts, but typically charges for mutual funds and other types of investments. The Advisor sponsors the Legacy Capital Wrap Fee Program. The sole purpose of this Wrap Fee Program Brochure is to provide additional disclosure relating the combination of Covered Costs into a single “bundled” investment advisory fee. This Wrap Fee Program Brochure references back to the Legacy Capital Disclosure Brochure in which this Wrap Fee Program Brochure serves as an Appendix. Please see Item 4 – Advisory Services of the Disclosure Brochure for details on Legacy Capital’s investment philosophy and related services. B. Program Costs Advisory services provided by Legacy Capital are offered in a wrap fee structure whereby Covered Costs are included in the overall investment advisory fee paid to Legacy Capital. As the level of activity in a Client’s account[s] may vary from year to year, the annual cost to the Client may be more or less than engaging for advisory services where the Covered Costs are borne separately by the Client. The cost of the Wrap Fee Program varies depending on services to be provided to each Client, however, the Client is not charged more if there is higher trading activity or other Covered Costs. A Wrap Fee structure presents a conflict of interest as the Advisor is incentivized to limit the number of trades placed in the Client’s account[s] or to utilize securities that do not have transaction fees. As noted above, the Advisor’s recommended Custodians do not charge securities transaction fees for ETF and equity trades in Client accounts, but typically charge for mutual funds and other types of investments. As such, the Advisor is incentivized to utilize ETFs and other equity securities to limit the overall cost to the Advisor. The Advisor will only place Client assets into a Wrap Fee Program when it is believed to be in the Client’s best interest. Please see Item 5 – Fees and Compensation of the Disclosure Brochure for complete details on fees. 3  C. Fees Investment Management Services Legacy Capital charges an annual advisory fee that is agreed upon with each Client and set forth in an agreement executed by Legacy Capital and the Client. Legacy Capital and any Client may, however, agree to adjust the fee annually or on a more frequent basis. Legacy Capital’s fee for investment advisory services is negotiable and varies based on a multitude of factors, including, but not limited to, the size of the relationship and the nature and complexity of the products and investments involved, service intensity, degree of custom work, time requirement, number of entities, number of family members served and travel requirements. The fee can be based on a percentage of assets under management or a fixed dollar amount. If based on a percentage of the value of assets under management, the fee generally ranges between 0.50% and 1.50% annually of the Client’s net billable assets under management. If based on a percentage of the value of assets under management, the initial advisory fee for the first calendar quarter (or part thereof) in which the Client enters into an advisory agreement with Legacy Capital shall be calculated on the day after initial assets are placed with Legacy Capital and shall be the advisory fee for the first calendar quarter (or part thereof). The initial advisory fee for any partial quarter is payable on a pro rata basis based on the number of calendar days in the partial quarter and is paid in the month following the establishment of the Client account. For subsequent quarters, the advisory fee generally is payable in advance (except for services to participant-directed 401k plans, which are payable either in advance or arrears, depending on the terms of the agreement), based on the market value of assets under management on the last business day of the prior calendar quarter. If a fixed dollar amount, the advisory fee for the initial quarter is payable, on a pro rata basis, in arrears. For subsequent quarters, the fixed fee generally is payable in advance. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Legacy Capital generally requires a minimum balance of assets under management per household of $500,000; this requirement may be waived solely in the discretion of the Advisor. As noted above, the Wrap Fee Program includes Covered Costs incurred in connection with the discretionary investment management services provided by Legacy Capital, as part of its overall investment advisory fee. 4  In addition, all fees paid to Legacy Capital for investment advisory services or part of the Wrap Fee Program are separate and distinct from the expenses charged by mutual funds and exchange- traded funds to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. Securities transaction fees for Client-directed trades will be charged back to the Client. In connection with the discretionary investment management services provided by Legacy Capital, the Client will incur other costs assessed by the Custodian or other third parties, other than the Covered Costs noted above, such as [wire transfer fees, fees for trades executed away from the Custodian and other fees]. The Advisor does not control nor share in these fees. The Client should review both the fees charged by the fund[s] and the fees charged by Legacy Capital to fully understand the total fees to be paid. Please see Item 5.C. – Other Fees and Expenses in the Disclosure Brochure (included with this Wrap Fee Program Brochure). D. Compensation Legacy Capital is the sponsor and portfolio manager of this Wrap Fee Program. Legacy Capital receives investment advisory fees paid by Clients for participating in the Wrap Fee Program and pays the Covered Costs associated with the management of the Client’s account[s]. Item 5 – Account Requirements and Types of Clients Legacy Capital offers investment advisory services to individuals, high net worth individuals, families, family offices, trusts, estates, businesses, charitable organizations, nonprofit organizations and retirement/profit-sharing plans. Legacy Capital generally requires a minimum balance of assets under management per household of $500,000; this requirement may be waived solely in the discretion of the Advisor. Please see Item 7 – Types of Clients in the Disclosure Brochure for additional information. Item 6 – Portfolio Manager Selection and Evaluation Portfolio Manager Selection Legacy Capital serves as sponsor and as portfolio manager for the services under this Wrap Fee Program. Related Persons Legacy Capital personnel serve as portfolio managers for this Wrap Fee Program. Legacy Capital does not serve as a portfolio manager for any third-party Wrap Fee Programs. 5  Performance-Based Fees Legacy Capital does not charge performance-based fees or participate in side-by-side management. Performance-based fees are fees that are based on a share of a capital gains or capital appreciation of a Client’s account. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. Legacy Capital’s fees are calculated as described in Item 5 above. Supervised Persons Legacy Capital Advisory Persons serve as portfolio managers for all accounts, including the services described in this Wrap Fee Program Brochure. Details of the advisory services provided are included in Item 4.A. of the Disclosure Brochure. Methods of Analysis Please see Item 8 of the Disclosure Brochure (included with this Wrap Fee Program Brochure) for details on the research and analysis methods employed by the Advisor. Risk of Loss All investments and investment programs have a variety of risks that are borne by the investor. As such, there can be no assurance that any investment strategy will prove profitable or successful. A Client can lose all or a substantial portion of his/her investment. A Client should be willing to bear such a loss. Some investments are intended only for sophisticated investors and can involve a high degree of risk. The following risks could cause equities, fixed-income securities, mutual funds, ETFs, alternative investments, and other investments in Client portfolios to decrease in value: • Market Risk: The price of an equity security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, changes in political, economic and social conditions may trigger adverse market events. • ETF Risk: The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. 6  • Mutual Fund Risk: The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • Event Risk: An adverse event affecting a particular company or that company’s industry could depress the price of a Client’s investments in that company’s stocks or bonds. The company, government or other entity that issued bonds in a Client’s portfolio could become less able to, or fail to, repay, service or refinance its debts, or the issuer’s credit rating could be downgraded by a rating agency. Adverse events affecting a country, including political and economic instability, could depress the value of investments in issuers headquartered or doing business in that country. • Liquidity Risk: Securities that are normally liquid may become difficult or impossible to sell at an acceptable price during periods of economic instability or other emergency conditions. Some securities may be infrequently or thinly traded even under normal market conditions. • Leverage Risk: The use of leverage may lead to increased volatility of a fund’s NAV and market price relative to its common shares. Leverage is likely to magnify any losses in the trust/fund’s portfolio, which may lead to increased market price declines. Fluctuations in interest rates on borrowings or the dividend rates on preferred shares that take place from changes in short- term interest rates may reduce the return to common shareholders or result in fluctuations in the dividends paid on common shares. There is no assurance that a leveraging strategy will be successful. • Domestic and/or Foreign Political Risk: The events that occur in the U.S. relating to politics, government, and elections can affect the U.S. markets. Political events occurring in the home country of a foreign company such as revolutions, nationalization, and currency collapse can have an impact on the security. • Inflation Risk: Countries around the globe may be more, or less, prone to inflation than the U.S. economy at any given time. Companies operating in countries with higher inflation rates may find it more difficult to post profits reflecting its underlying health. 7  • Currency Risk: Overseas investments are subject to fluctuations in the value of the U.S. dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This risk is that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. • Operational Risk: Fund Advisors and other ETF service providers may experience disruptions or operating errors such as processing errors or human errors, inadequate or failed internal or external processes, or systems or technology failures, that could negatively impact the ETF. • Regulatory/Legislative Developments Risk: Regulators and/or legislators may promulgate rules or pass legislation that places restrictions on, adds procedural hurdles to, affects the liquidity of, and/or alters the risks associated with certain investment transactions or the securities underlying such investment transactions. Such rules/legislation could affect the value associated with such investment transactions or underlying securities • Illiquid Securities: Investments in hedge funds and other private investment funds may underperform publicly offered and traded securities because such investments: o Typically require investors to lock‐up their assets for a period and may be unable to meet redemption requests during adverse economic conditions; o Have limited or no liquidity because of restrictions on the transfer of, and the absence of a market for, interests in these funds; o Are more difficult to monitor and value due to a lack of transparency and publicly available information about these funds; o May have higher expense ratios and involve more inherent conflicts of interest than publicly traded investments; and o Involve different risks than investing in registered funds and other publicly offered and traded securities. These risks may include those associated with more concentrated, less diversified investment portfolios, investment leverage and investments in less liquid and non‐traditional asset classes. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. 8  Clients are reminded to discuss these risks with the Advisor. Please see Item 8.B. – Risk of Loss in the Disclosure Brochure for details on investment risks. Proxy Voting Legacy Capital does not accept the authority to and does not vote proxies on behalf of Clients. Clients retain the responsibility for receiving and voting proxies for all and any securities maintained in Client portfolios. Clients may direct proxies to Legacy Capital; however, Legacy Capital will take no action on voting proxies. Item 7 – Client Information Provided to Portfolio Managers Legacy Capital is the sponsor and sole portfolio manager for the Program. The Advisor does not share Client information with other portfolio managers because it is the sole portfolio manager for this Wrap Fee Program. Please also see the Legacy Capital Privacy Policy (included after this Wrap Fee Program Brochure). Item 8 – Client Contact with Portfolio Managers Legacy Capital is a full-service investment management advisory firm. Clients always have direct access to the Portfolio Managers at Legacy Capital. Item 9 – Additional Information A. Disciplinary Information and Other Financial Industry Activities and Affiliations Registered investment advisors are required to disclose all material facts regarding any legal or disciplinary events that would be material to a Client’s evaluation of Legacy Capital and the integrity of Legacy Capital’s management. Legacy Capital has no information applicable to this Item. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor and its Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 291960. Please see Item 9 of the Legacy Capital Disclosure Brochure as well as Item 3 of each Advisory Person’s Brochure Supplement (included with this Wrap Fee Program Brochure) for additional information on how to research the background of the Advisor and its Advisory Persons. 9  Other Financial Activities and Affiliations Please see Item 10 – Other Financial Activities and Affiliation and Item 14 – Client Referrals and Other Compensation of the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee Program Brochure). B. Code of Ethics, Review of Accounts, Client Referrals, and Financial Information Legacy Capital has implemented a Code of Ethics that defines the Advisor’s fiduciary commitment to each Client. This Code of Ethics applies to all persons subject to Legacy Capital’s compliance program (our “Supervised Persons”). Complete details on the Legacy Capital Code of Ethics can be found under Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading in the Disclosure Brochure (included with this Wrap Fee Program Brochure). Inves Review of Accounts Client accounts are monitored on a regular and continuous basis by Advisory Persons of Legacy Capital under the supervision of the Chief Compliance Officer (“CCO”). Details of the review policies and practices are provided in Item 13 of the Form ADV Part 2A – Disclosure Brochure. Other Compensation Participation in Institutional Advisor Platform Legacy Capital has engaged two qualified custodians and will generally recommend that portfolio management Clients establish accounts with either Charles Schwab or Fidelity, both registered broker-dealers, member SIPC, to maintain custody of Clients’ assets and to effect trades for their accounts. Fidelity Legacy Capital maintains an institutional relationship with Fidelity Clearing & Custody Solutions, and related entities of Fidelity Investments, Inc. (collectively “Fidelity”) whereby Legacy Capital receives certain benefits. Legacy Capital may receive from Fidelity, without cost to Legacy Capital, computer software and related systems support, which allow Legacy Capital to better monitor Client accounts maintained at Fidelity, facilitate trade execution (and allocation of aggregated trade orders for multiple Client accounts), provide research, pricing information and other market data and assist with back-office functions, recordkeeping and Client reporting. Legacy Capital may receive the software and related support without cost because Legacy Capital renders investment management services to Clients that maintain assets at Fidelity. Specifically, Legacy Capital may receive the following benefits from Fidelity: receipt of duplicate Client confirmations and bundled duplicate statements, access to a trading desk that exclusively services its Registered Investment Adviser Group participants and access to an electronic communication network for Client account information. In addition, Fidelity also 10  makes available to Legacy Capital other services intended to help Legacy Capital manage and further develop its business enterprise. These services may include publications and conferences on practice management, information technology and regulatory compliance. Legacy Capital is independently owned and operated and not affiliated with Fidelity. Fidelity provides Legacy Capital with access to its institutional trading and custody services, which are typically not available to Fidelity retail investors. These services are generally available to independent investment advisors on an unsolicited basis and are not otherwise contingent upon Legacy Capital committing to Fidelity any specific amount of business (assets in custody or trading). For Legacy Capital’s Client accounts maintained there, Fidelity is compensated through commissions or other transaction-related fees for securities trades that are executed through Fidelity or that settle into Fidelity accounts. The brokerage commissions and/or transaction fees charged by Fidelity or any other designated broker-dealer are exclusive of and in addition to Legacy Capital’s fees. Any commissions paid by Legacy Capital’s Clients shall comply with Legacy Capital’s duty to obtain “best execution.” However, a Client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction where Legacy Capital determines, in good faith, that the commission is reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including among others, the value of research provided, execution capability, commission rates, and responsiveness. Consistent with the foregoing, while Legacy Capital will seek competitive rates, it may not necessarily obtain the lowest possible commission rates for Client transactions. Charles Schwab Advisors Services Legacy Capital has also established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent Advisors like Legacy Capital. As a registered investment advisor participating on the Schwab Advisor Services platform, Legacy Capital receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. 11  Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back-office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may not directly benefit all Clients. Services that May Only Benefit the Advisor – Schwab also offers other services and financial support to Legacy Capital that may not benefit the Client, including: educational conferences and events, financial start-up support, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a conflict of interest. Legacy Capital believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. Please se Item 14 – Other Compensation in the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee Program Brochure) for details on additional compensation that may be received by Legacy Capital or its Advisory Persons. Each Advisory Person’s Brochure Supplement (also included with this Wrap Fee Program Brochure) provides details on any outside business activities and the associated compensation. Compensation for Client Referrals Legacy Capital does not compensate, either directly or indirectly, any persons who are not supervised persons, for Client referrals. Item 10 – Financial Information A. Balance Sheet Legacy Capital does not require prepayment of more than $1,200 in fees per Client, six months or more in advance, and therefore does not need to include a balance sheet with this Disclosure Brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Legacy Capital nor its management has any financial conditions that are reasonably likely to impair its ability to meet contractual commitments to Clients. 12  C. Bankruptcy Petitions in Previous Years Legacy Capital has not been the subject of a bankruptcy petition. 13