Lesko Securities, Inc.

Item 1 – Cover Page Wrap Fee Program Brochure (Part 2A, Appendix 1 of Form ADV) Lesko Securities, Inc. 400 Plaza Drive, STE A, Vestal, NY 13850 (607) 724-2421 FAX (607) 724-2467 www.leskofinancial.com info@leskofinancial.com This brochure provides information about the qualifications and business practices of Lesko Securities, Inc. If you have any questions about the contents of this brochure, please contact us at: (607) 724-2421, or by email at: info@leskofinancial.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about Lesko Securities, Inc. is available on the SEC’s website at www.adviserinfo.sec.gov. March 2026 i  Item 2 - Material Changes Annual Update Since our last annual amendment filing on 03/13/2025 we have the following material changes to disclose: 1. We have added the option of discretionary management to our Wrap program offerings; and 2. We have updated and amended our Wrap program fee schedule. In the future, this section of the Brochure will discuss only the specific material changes that were made to the Brochure and will provide you with a summary of all material changes that have occurred since the last filing of this Brochure. This section will also identify the date of our last annual Brochure update. We will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal year end which is December 31. We will provide other ongoing disclosure information about material changes as they occur. We will also provide you with information on how to obtain the complete brochure. Currently, our Brochure can be requested at any time, without charge, by contacting Gregory Lesko at (607) 724-2421. ii  Item 3 - Table of Contents ITEM 1 – COVER PAGE .................................................................................................................................................. i ...I ITEM 2 - MATERIAL CHANGES ...................................................................................................................................... ii ..2 ITEM 3 - TABLE OF CONTENTS ...................................................................................................................................... 1 ITEM 4 - SERVICES, FEES AND COMPENSATION ............................................................................................................ 2 ITEM 5 - ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ........................................................................................ 6 ITEM 6 - PORTFOLIO MANAGER SELECTION AND EVALUATION .................................................................................... 6 ITEM 7 - CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ..................................................................... 10 ITEM 8 - CLIENT CONTACT WITH PORTFOLIO MANAGERS ........................................................................................... 10 ITEM 9 - ADDITIONAL INFORMATION ........................................................................................................................ 10 1 Lesko Financial Services  Item 4 - Services, Fees and Compensation Lesko Securities, Inc. (hereinafter “LSI”) is a corporation organized in the State of Delaware. The firm was formed in November 1980 as a broker-dealer firm and became registered as an investment adviser in 1989. Principal Owners Lesko Financial Services, Inc. is the parent company of Lesko Securities, Inc. the registered broker/dealer and Registered Investment Adviser. Gregory S. Lesko is the principal owner and majority stockholder of Lesko Financial Services, Inc. Lesko Securities, Inc. does not provide a timing service at this time. A Wrap Program is an investment advisory program that provides clients with asset management and brokerage services for one all-inclusive fee. If you participate in our wrap fee program, you will pay the firm a single fee, which includes money management fees, certain transaction costs, and custodial and administrative costs. You are not charged separate fees for respective components of the total services. LSI’s Wrap Fee Program is offered on the Charles Schwab platform where such securities as stocks, Mutual funds, bonds, ETF’s, ETN’s, UIT’s and options, all of which have trading costs associated with them, are offered. Client Investment Process Your Financial Advisor will obtain your financial data and assist you in determining the suitability of the Program based on the information obtained from you. We will use the suitability information we gather from you in our initial meeting to develop a strategy that enables our firm to give you continuous and focused investment advice and/or to make investment recommendations on your behalf. We will monitor your portfolio’s performance on an on-going basis and will rebalance the portfolio as required by changes in market conditions and in your financial circumstances. We will provide these services on a non- discretionary basis, meaning we will consult with you prior to making any trades, or a discretionary basis, where you grant us authority to make trades without your prior consent. Upon entering into an Investor Advisory Agreement, you will open an account with Charles Schwab, an unaffiliated and independent qualified custodian. Charles Schwab will provide you with services related to custody of securities, trade execution, and trade clearance and settlement. We will not have custody of client funds or securities, except to the limited extent of having Charles Schwab act as a paying agent for our firm by automatically deducting Program fees from your account(s). 2  Changes in Your Financial Circumstances In providing the contracted services, we are not required to verify any information we receive from you or from your other professionals (e.g., attorney, accountant, etc.) and we are expressly authorized to rely on the information you provide. Furthermore, unless you indicate to the contrary, we shall assume that there are no restrictions on our services, other than to manage your account in accordance with your designated investment objectives. It is your responsibility to promptly notify us if there are changes in your financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. The Wrap Program Fee We charge an annual “wrap fee” for participation in the Program depending upon the market value of your assets under management. You are not charged separate fees for the different components of services provided by the Program. Our firm pays all transaction expenses of trades placed on your behalf. Our Program fee includes the portfolio management fee and Charles Schwab’s transaction or execution costs. Assets in each of your account(s) are included in the fee assessment unless specifically identified in writing for an exclusion. In special circumstances, and in our sole discretion, we may negotiate a lesser management fee based upon certain criteria (i.e., anticipated future earning capacity, dollar amount of assets to be managed, related accounts, account composition, pre-existing client relationship, account retention, etc.) On an annualized basis, our Program fees as follows: Account Value/AUM Financial Advisor Annual Fee $0 - $999,999 1.05% $1,000,000 - $1,499,999 0.95% $1,500,000 - $1,999,999 $2,000,000 -2,499,999 $2,500,000 - $2,999,999 $3,000,000 - $3,499,999 $3,500,000+ 0.85% 0.75% 0.65% 0.60% 0.55% 3  For all Wrap Programs offered by LSI, your Wrap Fee will be assessed on a quarterly basis, in advance, of the calendar quarter. The advisory fee is calculated utilizing the method of taking the end of period balance plus weighted cash flows. This method will account for the balance at the end of the period plus any cash flows to and from the account during the billing period. The specific manner in which your advisory fees are calculated and charged is established in your written advisory agreement with LSI. In your investment advisory agreement, you must authorize to directly debit advisory fees from your account. Advisory fees are in most cases automatically deducted on a quarterly basis in advance from cash/money market positions or by liquidating assets held within the account. LSI may waive or negotiate fees at our sole discretion. Accounts opened during a calendar quarter will be charged a daily pro-rated fee based on the number of days advisory services were provide in that quarter. Upon closing of an account, any prepaid unearned fees will be refunded on a pro-rated basis and any earned, unpaid fees will be due and payable. In determining whether to establish an LSI Wrap Fee Program account, a client should be aware that the overall cost to the client of the Program may be higher or lower than the client might incur by purchasing separately the types of securities available in the Program. In order to compare the cost of the Program with unbundled services, the client should consider the turnover rate of our investment strategies, trading activity in the account, standard advisory fees and brokerage commissions that would be charged at Charles Schwab or at other broker-dealers and/or investment advisors. Termination of Advisory Relationship The client or investment advisor may terminate the wrap fee program agreement upon notice to the other party. You will incur a pro rata charge for services rendered prior to the termination of the wrap fee program agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a client. If you have pre-paid advisory fees that we have not yet earned, you will receive a pro-rated refund for those fees into your account when you give us timely notice of termination to allow us to refund these fees to your account prior to transfer/withdrawal. When a copy of the brochure is not provided to the client at least 48 hours prior to signing the contract, the client has five business days in which to cancel the contract without penalty. Upon termination of accounts held at Charles Schwab, they will deliver securities and funds held in the account per your instructions unless you request that the account be liquidated. After the wrap fee program arrangement has been terminated, transactions are processed at the prevailing brokerage rate/fees. You become responsible for monitoring your own assets and our firm has no further obligation to act upon or to provide advice with respect to those assets. 4  Wrap Fee Program Disclosures Wrap Fee Programs may not be suitable for all investment needs, and any decision to participate in a wrap fee program should be based on your financial situation, investment objectives, tolerance for risk, and investment time horizon, among other considerations. The benefits under a wrap program depend, in part, upon the size of the account and the number of transactions likely to be generated in the account. For example, a wrap fee program may not be suitable for accounts with little trading activity. In order to evaluate whether a wrap fee program is suitable for you, you should compare the Program fee and any costs with the Program with the amounts that would be charged by other advisors, broker-dealers, and custodians, for advisory fees, brokerage and execution costs, and custodial services comparable to those provided under the Programs. Participating in a wrap fee program may cost more or less than the cost of purchasing advisory, brokerage, and custodial services separately from third parties. LSI and its Advisors receive compensation as a result of your participation in the Program. This compensation may be more or less than the amount the firm or the Advisor would receive if you paid separately for investment advice, brokerage and other services. Accordingly, a conflict of interest exists because the firm and the Advisor may have a financial incentive to recommend the Program and may recommend the Program over other programs or services for which compensation arrangements are not as beneficial. Additional Fees and Expenses The Program Fee includes the costs of brokerage commissions for transactions executed through Charles Schwab, and charges relating to settlement, clearance, or custody of securities in the Account. The Program fee does not include mark-ups and mark downs, dealer spreads, interest, taxes or other costs, such as costs associated with exchanging currencies, wire transfer fees, transactions not executed through Charles Schwab, or other fees required by law or imposed by third parties. The wrap program fees that you pay the firm for portfolio management services are separate and distinct from the fees and expenses charged by mutual funds or exchange traded funds (described in each fund’s prospectus) to their shareholders. These fees will generally include a management fee and other fund expenses. The management fee is usually called an expense ratio. For example, an expense ratio of 0.50 means that the mutual fund company charges 0.50% for their services. This fee is in addition to the fee paid by you to LSI. Performance figures quoted by mutual fund companies in various publications are after their fees have been deducted. To fully understand the total cost you will incur, you should review all the fees charged by mutual funds, exchange traded funds, our firm, and others. If required, a client may pay other fees and expenses including but not limited to, debit and check writing fees, ATM fees and etc. See the Charles Schwab schedule of fees for the complete list. 5  LSI possesses written authorization from the client to deduct advisory fees from an account held by a qualified custodian. LSI sends the qualified custodian written notice of the amount of the fee to be deducted from the client’s account. ITEM 5 - Account Requirements and Types of Clients The majority of LSI’s clients are individuals with personal accounts, trusts and individual retirement accounts. LSI may provide advice to corporations, businesses, pension and profit-sharing plans, estates, and charitable organizations. ITEM 6 - Portfolio Manager Selection and Evaluation Our firm does not utilize outside portfolio managers. All accounts are managed by our in- house professionals. Our firm and its related persons act as portfolio manager(s) for this wrap fee program. This may create a conflict of interest in that other investment advisory firms may charge the same or lower fees than our firm for similar services. Our related person portfolio managers are not subject to the same selection and review as outside portfolio managers that participate in the wrap fee program. This is because we have chosen not to utilize outside portfolio managers. Our firm and supervised persons act as portfolio manager(s) for this wrap fee program. LSI’s Investment methodology incorporates our own Investment philosophies and beliefs, such as the benefits of low cost, diversification and consistent fund manager performance. Our methodology is driven by long-term financial goals, not by market- timing or short-term investment performance. Rather than attempting to predict which investments will provide superior performance at any given time, LSI generally believes that maintaining a broadly diversified portfolio, including investments from a variety of market sectors and asset classes that focuses on maximizing after tax returns can provide the best opportunity for success. Asset classes include, but are not limited to, domestic and international equities, domestic and international bonds, cash and cash equivalents, as well as alternative investment types such as real estate and commodity funds. Equities can further be broken down by market capitalization (company size based on annual revenues) ranging from large companies (large-cap) to medium and small companies (mid-cap and small-cap). Bonds meanwhile can be further broken down by issuer type- such as corporate, municipal and government- and by duration, ranging from short term to long. 6  LSI primarily utilizes no-load, load waived or advisor share class Mutual funds along with ETF’s, ETN’s and UIT’s in its Wrap Program. Mutual funds pool the money of its investors and invest in a variety of stocks, bonds or other types of securities to meet the stated objective of the fund. Actual Investment return and principal value of most mutual fund investments are subject to market risk and will fluctuate so that your shares, when redeemed, may be worth more or less than their original cost. The underlying investments of mutual funds are subject to the risks associated with the corresponding asset classes. Using a risk appropriate diversified portfolio, LSI uses two approaches to further manage your money in its Wrap Fee Program. A strategic approach and a Tactical approach. Both approaches are best suited for a long-term objective to investing. Strategic: A strategy that sets specific asset class allocations and then periodically rebalances the managed portfolio to maintain the original asset class allocation. Tactical: A strategy that takes a more active trading approach to investing that makes tactical trades in your portfolio in an attempt to take advantage of potential market opportunities. There are specific mutual funds and ETF’s, generally speaking, that are targeted to be strategic and/or tactical in nature. We may use one or more of the following methods of analysis or investment strategies when providing investment advice to you. Technical Analysis and Charting - “Technical Analysis”, sometimes also known as “charting” is a method of evaluating securities by analyzing statistics generated by market activity, such as past prices and trading volume. In technical analysis it is not attempted to measure a security’s intrinsic value (value based on company’s financial status, cash flow and net worth, etc.), but instead to use historical charts and other tools to identify patterns that can suggest future activity. Cyclical Analysis - Similar to Charting, “Cyclical Analysis” attempts to suggest the future activity of the prices of securities based on the theory that prices move in a cyclical pattern. This method of analysis uses market cycles (the general expansion and contraction of business) as the primary driver. This method of analysis does not take under consideration the intrinsic value (value based on company’s financial status, cash flow, net worth, etc.) of the security being evaluated. 7  Fundamental Analysis - involves analyzing individual companies and their industry peer groups, such as a company’s financial statements, details regarding the company’s product line, the experience and expertise of the company’s management, and the outlook for the company and the industry. The resulting data is used to measure the true value of the company’s stock compared to the current market value. None of the methods above guarantee the successful prediction of future securities pricing. In practice, the various methods of analysis are often used in concert with one another in analyzing securities. Information about the securities being analyzed may come from a variety of sources. These sources may include financial newspapers and magazines, research materials prepared by industry analysts, corporate rating services (such as Morningstar®, Argus Research, Moody’s, Standard & Poor’s, etc.) company press releases, and annual reports or prospectuses filed with the Securities and Exchange Commission. (It should be noted that neither LSI nor its advisors prepare “research reports” internally.) Our investment strategies and advice may vary depending upon each client’s specific financial situation. As such, we determine investments and allocations based upon your predefined objectives risk tolerance, time horizon, financial information, liquidity needs, and other various suitability factors. Regardless of the investing strategy employed, investing in securities involves risk of loss that you should be prepared to bear. There is no investing strategy that can guarantee you against loss. Risk of Loss All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment risks: • 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. • Market Risk: The price of a 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, political, economic and social conditions may trigger market events. • Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. 8  • Reinvestment Risk: This is the risk 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. • Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Performance-Based Fees and Side by Side Management We do not accept performance-based fees or participate in side-by-side management. Performance-based fees are fees that are based on a share of 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 performance-based fees. Voting Client Securities Proxy Votes LSI does not vote proxies on securities. Clients are expected to vote their own proxies. When assistance on voting proxies is requested, LSI will provide recommendations to the Client. If a conflict of interest exists, it will be disclosed to the Client. 9  ITEM 7 - Client Information Provided to Portfolio Managers The advisors of LSI are the portfolio managers of their client’s accounts. Our advisors communicate directly with their clients on a regular basis and as certain conditions warrant. Clients can communicate directly to their advisor any changes in personal information, changes to their strategy or goals and any other relevant information. ITEM 8 - Client Contact with Portfolio Managers The client can direct any questions or comments directly to our firm, LSI, or their investment advisor. ITEM 9 - Additional Information Disciplinary Information Legal and Disciplinary The firm and its employees have not been involved in legal or disciplinary events related to past or present investment advisory clients. Other Financial Industry Activities and Affiliations Financial Industry Activities Lesko Securities, Inc. is registered as a securities broker-dealer. Management personnel, Gregory Lesko and Karen Stebbins are also registered representatives of Lesko Securities, Inc. Investment advisors of LSI may be registered representatives and be licensed to sell insurance products. Insurance products will not be offered to Pennsylvania clients unless the investment advisor representative is appropriately licensed to sell insurance products in the state of Pennsylvania. Affiliations LSI has a relationship as an introducing broker with National Financial Services, Inc. (“NFS”) as clearing broker. LSI also has an arrangement with Charles Schwab as a custodian for RIA accounts only. There are no other material arrangements with its advisory or its clients with a related person who is a broker-dealer, investment company, other investment advisor, financial planning firm, commodity pool operator, commodity trading adviser or futures commission merchant, banking or thrift institution, accounting firm, law firm, pension consultant, real estate broker or dealer, or an entity that creates or packages limited partnerships. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The employees of Lesko Securities, Inc. have committed to a Code of Ethics covering 10  Integrity, Objectivity, Competence, Fairness and Disclosure, the areas of Professionalism and Diligence. The firm will provide a copy of the Code of Ethics to any client or prospective client upon request. A copy is also available at the firm’s website: www.leskofinancial.com. Participation or Interest in Client Transactions LSI and its employees may buy or sell securities that are also held by clients. Employees may not trade their own securities ahead of client trades. Employees comply with the provisions of the LSI Compliance Manual. Personal Trading The Chief Compliance Officer of Lesko Securities, Inc. is Gregory S. Lesko. He reviews all employee trades each quarter. His trades are reviewed by Karen Stebbins or Nik Lalovic. The personal trading reviews ensure that the personal trading of employees does not affect the markets, and that clients of the firm receive preferential treatment. Since most employee trades are small mutual fund trades or exchange- traded fund trades, the trades do not affect the securities markets. Brokerage Practices Leso Securities, Inc. has a clearing relationship with National Financial Services LLC (NFS). NFS acts as custodian and clearing firm. Among other things, NFS carries accounts, executes and clears transactions for Lesko Securities, Inc. Lesko Securities, Inc has a custody relationship with Charles Schwab. Charles Schwab acts as custodian and clearing firm for RIA accounts only. Lesko Securities, Inc. does not receive additional fees or commissions from any of these arrangements. Soft Dollars Lesko Securities, Inc. may enter into soft dollar arrangements through which it may receive research, products, or other services from its broker/dealer Charles Schwab, or another third-party in connection with client securities transactions (“soft dollar benefits”) within (but not outside of) the safe harbor contained in Section 28€ of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and Lesko Securities, Inc. does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. Lesko Securities, Inc. benefits by not having to produce or pay for the research, products or services, and LSI, will have an incentive to recommend a broker/dealer based on receiving research or services. Clients should be aware that LSI’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 11  Review of Accounts Periodic Reviews Account reviews are performed annually by the advisors assigned to the account. Account reviews are performed more frequently when market conditions dictate. Review Triggers Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's own situation. Regular Reports Reports may consist of an individualized letter summarizing their positions, the advisor’s thoughts on current market conditions, Morningstar® reports and/or snapshots, or other necessary information. Clients receive periodic communications on at least an annual basis. Client Referrals and Other Compensation Incoming Referrals LSI has been fortunate to receive many client referrals over the years. The referrals came from current clients, estate planning attorneys, accountants, employees, personal friends of employees and other similar sources. The firm does not compensate referring parties for these referrals. Referrals Out LSI does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Other Compensation Your Advisor may have more than one relationship to you. An Investment Advisor is making recommendations on your advisory account and a Registered Representative is receiving compensation for the sale of securities or insurance products. Investment advisors may also be registered representatives of LSI and insurance agents of Lesko Financial Services and therefore earn commissions on selling products and insurance. This may represent a conflict of interest as there can be an incentive to sell a product or insurance for commission. Advisors may suggest broker/dealer services where compensation for a transaction(s) are considered a benefit over the advisory services. This compensation is separate from the investment advisory services you pay. Clients who participate in the wrap program are not charged a commission for the purchase or sale of securities in that program. 12  Occasionally an advisor will recommend a security that the advisor already owns. In these circumstances the advisor will adhere to the Code of Ethics policy. Account Statements All assets are held at qualified custodians, which means the custodians provide account statements directly to clients at their address of record at least quarterly. Performance Reports Clients are urged to compare the account statements received directly from their custodians to the statements provided by LSI. Investment Discretion Discretionary Authority for Trading LSI offers both discretionary and non-discretionary accounts allowing the client to decide which program is best for their situation. With non-discretionary accounts, LSI does not have the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. LSI consults with the client prior to each trade to obtain concurrence. For discretionary accounts, the Investment Advisory Contract established with each client will outline the discretionary authority for trading. Where investment discretion has been granted, LSI generally manages the client’s account and makes investment decisions without consultation with the client as to what securities to buy or sell, when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, or the price per share. Financial Information Financial Condition LSI does not have any financial impairment that will preclude the firm from meeting contractual commitments to clients. A balance sheet is not required to be provided because LSI does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. Business Continuity Plan General LSI has a Business Continuity Plan in place that provides detailed steps to mitigate and recover from the loss of office space, communications, services or key people. Disasters The Business Continuity Plan covers natural disasters such as snowstorms, 13  hurricanes, tornados, and flooding. The Plan covers man-made disasters such as loss of electrical power, loss of water pressure, fire, bomb threat, nuclear emergency, chemical event, biological event, T-1-communications line outage, Internet outage, railway accident and aircraft accident. Electronic files are backed up daily and archived offsite. Alternate Offices Alternate offices are identified to support ongoing operations in the event the main office is unavailable. It is our intention to contact all clients within five days of a disaster that dictates moving our office to an alternate location. Information Security Program Information Security LSI maintains an information security program to reduce the risk that your personal and confidential information may be breached. Privacy Notice LSI is committed to maintaining the confidentiality, integrity and security of the personal information that is entrusted to us. The categories of nonpublic information that we collect from you may include information about your personal finances, information about your health to the extent that it is needed for the financial planning process, information about transactions between you and third parties, and information from consumer reporting agencies, e.g., credit reports. We use this information to help you meet your personal financial goals. With your permission, we disclose limited information to attorneys, accountants, and mortgage lenders with whom you have established a relationship. You may opt out from our sharing information with these nonaffiliated third parties by notifying us at any time by telephone, mail, fax, email, or in person. With your permission, we share a limited amount of information about you with your brokerage firm in order to execute securities transactions on your behalf. We maintain a secure office to ensure that your information is not placed at unreasonable risk. We employ a firewall barrier, secure data encryption techniques and authentication procedures in our computer environment. We do not provide your personal information to mailing list vendors or solicitors. We require strict confidentiality in our agreements with unaffiliated third parties that require access to your personal information, including financial service companies, consultants, and auditors. Federal and state securities regulators may review our Company records and your personal records as permitted by law. Personally identifiable information about you will be maintained while you are a client, and for the required period thereafter that records are required to be maintained by federal and state securities laws. After that time, information may be destroyed. We will notify you in advance if our privacy policy is expected to change. We are required by law to deliver this Privacy Notice to you annually, in writing. 14 

Item 1 – Cover Page Lesko Securities, Inc. Firm Brochure - Form ADV Part2A This brochure provides information about the qualifications and business practices of Lesko Securities, Inc. If you have any questions about the contents of this brochure, please contact us at (607) 724-2421 or by email at: info@leskofinancial.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Lesko Securities, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. Lesko Securities, Inc.’s CRD number is: 10091. 400 Plaza Drive, STE A Vestal, NY 13850 (607) 724-2421 info@leskofinancial.com www.leskofinanical.com Registration does not imply a certain level of skill or training. Version Date: March 2026 i  Item 2: Material Changes Since our last annual amendment filing on 03/13/2025 we have the following material changes to disclose: 1. We have added the option of discretionary management to our Investment Advisory programs (see Item 16, page 18). 2. We have added offering American Funds CollegeAmerica 529 Plan advisory share classes (see Item 5, page 6). 3. We have updated and amended our fee schedules (see Item 5, pages 5-6). ii  Item 3: Table of Contents Item 1 – Cover Page ............................................................................................................................................................................................................................ 1 Item 2: Material Changes .................................................................................................................................................................................................................... 2 Item 3: Table of Contents .................................................................................................................................................................................................................... 3 Item 4: Advisory Business .................................................................................................................................................................................................................. 4 Item 5: Fees and Compensation ........................................................................................................................................................................................................... 5 Item 6: Performance-Based Fees and Side-By-Side Management ........................................................................................................................................................ 7 Item 7: Types of Clients ...................................................................................................................................................................................................................... 8 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss .................................................................................................................................................... 8 Item 9: Disciplinary Information ...................................................................................................................................................................................................... 11 Item 10: Other Financial Industry Activities and Affiliations ............................................................................................................................................................ 11 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......................................................................................................... 13 Item 12: Brokerage Practices ............................................................................................................................................................................................................ 14 Item 13: Review of Accounts ........................................................................................................................................................................................................... 15 Item 14: Client Referrals and Other Compensation ........................................................................................................................................................................... 16 Item 15: Custody.............................................................................................................................................................................................................................. 17 Item 16: Investment Discretion ........................................................................................................................................................................................................ 17 Item 17: Voting Client Securities (Proxy Voting) ............................................................................................................................................................................. 17 Item 18: Financial Information ......................................................................................................................................................................................................... 17 iii  Item 4: Advisory Business A. Description of the Advisory Firm Lesko Securities, Inc. (hereinafter “LSI”) is a corporation organized in the State of Delaware. The firm was formed in November 1980 as a broker-dealer firm and became registered as an investment adviser in 1989. The principal owner is Lesko Financial Services, Inc. Gregory S. Lesko is the majority owner of Lesko Financial Services, Inc. B. Types of Advisory Services Portfolio Management Services LSI offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. LSI creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring LSI evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. LSI seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of LSI’s economic, investment or other financial interests. To meet its fiduciary obligations, LSI attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, LSI’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is LSI’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Financial Planning Financial plans and financial planning may include but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. 4  Services Limited to Specific Types of Investments LSI generally limits its investment advice to mutual funds, fixed income securities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds and non-U.S. securities. LSI may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions LSI offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. D. Wrap Fee Programs LSI participates in wrap fee programs, which are investment programs where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. LSI manages the investments in the wrap fee program. Fees paid under the wrap fee program will be given to LSI as a management fee. E. Assets Under Management LSI has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $0 $728,519,170 December 31, 2025 Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees $0 - $1,000,000 1.00% $1,000,000 - $1,499,999 0.90% $1,500,000 - $1,999,999 0.80% $2,000,000 - $2,4999,999 0.70% $2,500,000 - $2,999,999 0.60% 5  $3,000,000 - $3,499,999 0.55% $3,500,000+ 0.50% The advisory fee is calculated utilizing the method of taking the end of period balance plus weighted cash flows. This method will account for the balance at the end of the period plus any cash flows to and from the account during the billing period. These fees are generally negotiable, and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Clients may terminate the agreement without penalty for a full refund of LSI's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract with timely notice to allow for refund of unearned fees to client’s account prior to transfer/withdrawal. CollegeAmerica 529 F-2 share class Advisory Fees With American Funds ® fund direct 529-F2 program our Advisory Fees are charged at a flat rate equal to an annual charge of 0.45% and are calculated quarterly in arrears and deducted by American Funds ® from the account and paid to us on a quarterly basis by applying the fee to the client’s accounts’ Average Daily Balance. Financial Planning Fees Hourly Fees The negotiated hourly fee for these services is between $120 and $400. Clients may terminate the agreement without penalty, for full refund of LSI’s fees, within five business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the Financial Planning Agreement generally upon written notice. B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis. Fees are paid in advance. Payment of Financial Planning Fees Financial planning fees are paid via check. Hourly financial planning fees are paid in arrears upon completion. C. Client Responsibility for Third Party Fees Clients are responsible for the payment of all third-party fees such as custodian fees, 6  brokerage fees, mutual fund fees, and transactions fees. Those fees are separate from the fees and expenses charged by LSI. Please see Item 12 for information about the custodian/broker-dealer. D. Prepayment of Fees LSI collects fees in advance. Refunds for fees paid in advance will be returned within thirty days to the client via check or return deposit back into the client’s account. For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee rate by 365.) Supervised persons of LSI are also registered broker-dealer representatives of LSI. In addition, supervised persons of LSI are licensed insurance agents. In these roles, they accept compensation for the sale of investment products to LSI clients. This is a Conflict of Interest Supervised persons may accept compensation for the sale of investment products, including asset-based sales charges or service fees from the sale of mutual funds to LSI's clients. This presents a conflict of interest and gives the supervised person an incentive to recommend products based on the compensation received rather than on the client’s needs. When recommending the sale of investment products for which the supervised persons receive compensation, LSI will document the conflict of interest in the client file and inform the client of the conflict of interest. Clients Have the Option to Purchase Recommended Products from Other Brokers Clients always have the option to purchase LSI recommended products through other brokers or agents that are not affiliated with LSI. Commissions are not LSI's primary source of compensation for advisory services Commissions are not LSI’s primary source of compensation for advisory services. Advisory Fees in Addition to Commissions or Markups Advisory fees that are charged to clients are not reduced to offset the commissions or markups on investment products recommended to clients. Item 6: Performance-Based Fees and Side-By-Side Management LSI does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. 7  Item 7: Types of Clients LSI generally provides advisory services to the following types of clients: ❖ ❖ ❖ ❖ ❖ ❖ Individuals and High-Net-Worth Individuals Trusts Estates Charities Pension and Profit-Sharing Plans Corporations and Businesses LSI requires a minimum account size of $25,000 which the firm may waive at its discretion. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis LSI’s methods of analysis include Charting analysis, Cyclical analysis, Fundamental analysis, Modern portfolio theory, Quantitative analysis and technical analysis. Charting analysis involves the use of patterns in performance charts. LSI uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. Technical analysis involves the analysis of past market data; primarily price and volume. 8  Investment Strategies LSI uses long term trading and short-term trading. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Charting analysis strategy involves using and comparing various charts to predict long and short-term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be making the assumption that past performance will be indicative of future performance. This may not be the case. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two- fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Quantitative analysis Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new 9  patterns that emerge over time. Investment Strategies Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Short term trading risks include liquidity, economic stability, and inflation, in addition to the long-term trading risks listed above. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best-known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential 10  risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative LSI is currently registered as a broker-dealer and management persons of LSI are registered broker-dealer representatives of LSI. 11  B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither LSI nor its management persons are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Supervised persons of LSI are also registered broker-dealer representatives of LSI and, from time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. LSI always acts in the best interest of the client, including with respect to the sale of commissionable products to advisory clients. Clients are in no way required to implement the recommendations through any representative of LSI in such individual’s capacity as a registered representative. The owner of LSI, Lesko Financial Services, Inc., is an insurance agency and supervised persons of LSI are licensed insurance agents with Lesko Financial Services, Inc. From time to time, they will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. LSI always acts in the best interest of the client; including the sale of commissionable products to advisory clients. Clients are in no way required to utilize the services of any representative of LSI in connection with such individual's activities outside of LSI. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections LSI does not utilize nor select third-party investment advisers. All assets are managed by LSI. 12  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics LSI has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. LSI's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests LSI does not recommend that clients buy or sell any security in which a related person to LSI or LSI has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of LSI may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of LSI to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. LSI will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of LSI may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of LSI to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, LSI will never engage in trading that operates to the client’s disadvantage if representatives of LSI buy or sell securities at or around the same time as clients. 13  Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers the market expertise and research access provided by Custodians/broker-dealers will be recommended based on LSI’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and LSI may also consider the broker- dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in LSI's research efforts. LSI will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. LSI will recommend clients use Charles Schwab Institutional, a division of Charles Schwab, Inc. Member FINRA/SIPC. Research and Other Soft-Dollar Benefits While LSI has no formal soft dollar’s program in which soft dollars are used to pay for third party services, LSI may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). LSI may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and LSI does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. LSI benefits by not having to produce or pay for the research, products or services, and LSI will have an incentive to recommend a broker- dealer based on receiving research or services. Clients should be aware that LSI’s acceptance of soft dollar benefits may result in higher commissions charged to the client. Brokerage for Client Referrals LSI receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. Clients Directing Which Broker/Dealer/Custodian to Use We do not recommend, request, require, or permit our clients to direct us to execute transactions through a specific broker-dealer. 14  B. Aggregating (Block) Trading for Multiple Client Accounts LSI does not aggregate or bunch the securities to be purchased or sold for multiple clients. This may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for LSI's advisory services provided on an ongoing basis are reviewed at least annually by the investment advisor representative assigned to the client with regard to clients’ respective investment policies and risk tolerance levels. All accounts at LSI are assigned to this reviewer. All financial planning accounts are reviewed upon financial plan creation and plan delivery by Gregory Lesko, CCO. Financial planning clients are provided a one-time financial plan concerning their financial situation. After the presentation of the plan, there are no further reports. Clients may request additional plans or reports for a fee. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). With respect to financial plans, LSI’s services will generally conclude upon delivery of the financial plan. C. Content and Frequency of Regular Reports Provided to Clients Each client of LSI's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. Each financial planning client will receive the financial plan upon completion. 15  Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) LSI participates in the institutional advisor program (the "Program") offered by Charles Schwab. Charles Schwab offers to independent investment advisor services which include custody of securities, trade execution, clearance and settlement of transactions. LSI receives some benefits from Charles Schwab through its participation in the Program. As disclosed above, LSI participates in Charles Schwab's institutional advisor program and LSI may recommend Charles Schwab to clients for custody and brokerage services. There is no direct link between LSI's participation in the Program and the investment advice it gives to its clients, although LSI receives economic benefits through its participation in the Program that are typically not available to Charles Schwab retail investors. These benefits include the following products and services (provided without cost or at a discount): receipt of duplicate client statements and confirmations; research related products and tools; consulting services; access to a trading desk serving LSI participants; access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts); the ability to have LSI's fees deducted directly from client accounts; access to an electronic communications network for client order entry and account information; access to mutual funds with no transaction fees and to certain institutional money managers; and discounts on compliance, marketing, research, technology, and practice management products or services provided to LSI by third party vendors. Charles Schwab may also pay for business consulting and professional services received by LSI's related persons. Some of the products and services made available by Charles Schwab through the Program may benefit LSI but may not benefit its client accounts. These products or services may assist LSI in managing and administering client accounts, including accounts not maintained at Charles Schwab. Other services made available by Charles Schwab are intended to help LSI manage and further develop its business enterprise. The benefits received by LSI or its personnel through participation in the Program do not depend on the amount of brokerage transactions directed to Charles Schwab. As part of its fiduciary duties to clients, LSI endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by LSI or its related persons in and of itself creates a conflict of interest and may indirectly influence the LSI's choice of Charles Schwab for custody and brokerage services. B. Compensation to Non – Advisory Personnel for Client Referrals LSI does not directly or indirectly compensate any person who is not advisory personnel for client referrals. 16  Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, LSI will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Item 16: Investment Discretion LSI manages client accounts on both a discretionary and non-discretionary basis, meaning we will consult with you prior to making any trades and a discretionary basis, meaning you grant us authority to make trades without your prior consent. Item 17: Voting Client Securities (Proxy Voting) LSI will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet LSI neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither LSI nor its management has any financial condition that is likely to reasonably impair LSI’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years LSI has not been the subject of a bankruptcy petition in the last ten years. 17