LEXINGTON INVESTMENT CONSULTING, LLC

Use Lexington Investment Consulting Logo Lexington Investment Consulting, LLC 424 Church Street, Suite 1550 Nashville, TN 37219 Meetings By Appointment Only Telephone: 615-492-1011 March 27, 2025 FORM ADV PART 2A BROCHURE This brochure provides information about the qualifications and business practices of Lexington Investment Consulting, LLC. If you have any questions about the contents of this brochure, contact us at 615-492-1011. 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 Lexington Investment Consulting, LLC is available on the SEC's website at www.adviserinfo.sec.gov. Lexington Investment Consulting, LLC is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. 1  Item 2 Material Changes Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially outdated. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since our last annual updating amendment, dated March 26, 2024 we made the following material changes to our Brochure. We revised Item 10 to remove the disclosure regarding Zeitlin Sotheby's International since the individual who held that real estate broker license is no longer with LIC. 2  Item 3 Table of Contents Item 1 Cover Page Item 2 Material Changes Item 3 Table of Contents Item 4 Advisory Business Item 5 Fees and Compensation Item 6 Performance-Based Fees and Side-By-Side Management Item 7 Types of Clients Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Item 9 Disciplinary Information Item 10 Other Financial Industry Activities and Affiliations Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 12 Brokerage Practices Item 13 Review of Accounts Item 14 Client Referrals and Other Compensation Item 15 Custody Item 16 Investment Discretion Item 17 Voting Client Securities Item 18 Financial Information Item 19 Requirements for State Registered Advisers Item 20 Additional Information Page 1 Page 2 Page 3 Page 4 Page 8 Page 10 Page 10 Page 11 Page 12 Page 12 Page 13 Page 13 Page 14 Page 14 Page 15 Page 15 Page 16 Page 16 Page 16 Page 16 3  Item 4 Advisory Business Lexington Investment Consulting, LLC is an investment adviser located in Nashville, Tennessee. Our firm has been in business since 2003 and the owner is Lexington Financial Life Management, LLC ("LFLM"). Dale Veitch is CEO and CCO. LFLM is primarily owned by Pure Acquisitions II, LLC ("Pure Acquisitions"). Pure Acquisitions is, in turn owned by the Forever Trust (Dale Veitch and Jeanette Veitch Co-Trustees). We are structured as a Virtual Family Office offering personalized investment advisory and financial guidance services to high net-worth and ultra high net-worth individuals and families, pensions and profit sharing plans, trusts, estates, charitable organizations, corporations and other business entities. The following paragraphs describe our services and fees. As used in this brochure, the words "we", "our" and "us" refer to Lexington Investment Consulting, LLC and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Investment Consulting Services Individuals associated with our firm will provide the firm's investment consulting services. These individuals are appropriately licensed, qualified or authorized to provide advisory services on our firm's behalf. Such individuals are known as Investment Adviser Representatives (IARs). Registration of an Investment Adviser Representative does not imply any level of skill or training. See the Form ADV Part 2B Supplement for further information regarding your Investment Adviser Representative. We provide investment consulting services on a discretionary basis, and, on occasion, on a non- discretionary basis. We will either customize a portfolio for you based on your individual facts and circumstances or we may use a model portfolio created by third party money managers. At the beginning of our relationship with you, we will conduct a personal interview. Through the interview, we obtain information about your current financial status, future goals and attitudes toward risk. Any documents you supply will be reviewed carefully. Then, we will give you a written proposal which includes a broad overview of the course of action we recommend for you. If you choose to proceed, we will work with you to implement the recommendations. Investment Consulting consists of the following: • Portfolio Analysis • Portfolio Asset Allocation • Portfolio Rebalancing • Portfolio Management Investing in securities may have unique and significant tax implications. We generally take tax efficiency into consideration in the management of your assets. Nonetheless, regardless of your account size or any other factors, we recommend that you consult with a tax professional when investing your assets. Professional management of your portfolio may include, but is not limited to, investing in stocks, bonds, real estate, mutual funds, exchange traded funds (ETFs), and cash equivalent instruments. Portfolios are designed based on your investment objectives, risk tolerance, net worth, net income, and various other suitability factors. 4  We manage our client accounts on an individualized basis. Further, our clients may impose restrictions on investing in certain securities or types of securities. These restrictions, which must be provided in writing, may affect composition and performance of portfolios. For these reasons, and others, performance of portfolios within the same investment objective may differ and you should not expect that performance of your portfolios will be identical with the average client of our firm. SEI Managed Account Program We participate in the Managed Account Program ("Program") through SEI Investment Management Corporation ("SEI"). SEI is a global leader of wealth management solutions with 50 plus years of experience in providing outsourced solutions to independent advisors. To participate in the Program, our firm, SEI and the individual investor executes a tri-party agreement ("Managed Account Agreement"). We utilize the services of SEI to manage your assets and provide portfolio management services. Pursuant to the Managed Account Agreement, you, as the investor, appoint our firm as your investment adviser to assist you in selecting an asset allocation strategy which would include the percentage of your assets to be allocated to designated portfolios of separate securities ("Managed Account Portfolio") and may include a percentage of assets allocated to a portfolio of mutual funds advised by SEI or an affiliate of SEI. You will further appoint SEI to manage the assets in each Managed Account Portfolio in accordance with a strategy selected by you together with our firm. SEI may delegate its responsibility for selecting particular securities to one or more portfolio managers. Under these arrangements, we gather information about your financial situation, investment objectives, and reasonable restrictions you may wish to impose on the management of your account. We then assist you in selecting a particular Program(s) for your account. Thereafter, we monitor the performance; review reports provided to you; communicate information to SEI as warranted; conduct periodic reviews of your account; and assist you in understanding and evaluating the services provided by SEI. Our primary objective is to align you with the appropriate Program to allow you to capitalize on opportunities that will strengthen or enhance your personal portfolio. SEI will actively manage your portfolio and will assume investment discretion and trading authority over the managed account. Under such arrangements, our firm will also obtain investment discretion to make changes to your account. We will assume discretionary authority to reallocate your accounts among different SEI Programs and give instructions to SEI to buy or sell for tax purposes, distributions, and/or reallocate your assets where such action is deemed to be in your best interest. Lexington Managed Accounts When appropriate for your needs, we may manage your account(s) directly. Such advice will typically involve providing a variety of services, which may include investment buy/sell recommendations and asset allocation, including the potential selection of mutual funds and/or exchange traded funds for your account based upon an analysis of your individualized needs, goals and objectives. Under such arrangements, our firm will assume full discretionary and trading authority over the investments held in your account. Refer to Item 16 below for additional disclosures on this topic. In limited circumstances, and at our discretion, we may enter into non-discretionary arrangements with advisory clients. When we enter into non-discretionary arrangements with our clients, we will obtain our client's approval prior to the execution of a trade. We do not represent, warrant or imply that the services or methods of analysis employed by our firm can or will predict future results, successfully identify market tops or bottoms, or insulate our clients from losses due to market corrections or declines. Refer to Item 8 below for additional disclosures on this topic. 5  We shall not have custody of any client funds or securities, as the services of an independent custodian will be used for these investment consulting services. Refer to Item 15 below for additional disclosures on this topic. While our firm endeavors at all times to offer our clients its specialized services at reasonable costs, the fees charged by other advisors for comparable services may be lower than the fees charged by our firm. Investment Analysis and Recommendation Service On a case-by-case basis, we may provide investment analysis and recommendations or investment consulting services not described above. You may, for example, engage us to provide recommendations or provide an analysis of your portfolio without retaining us to manage the account. Other topics we can address may include, but are not limited to, risk assessment/management, investment planning, financial organization, or financial decision making/negotiation. Wrap Fee Program(s) We act as an investment adviser for our client accounts in the SEI Investment Management Corporation ("SEI") Wrap Fee Program. The Wrap Fee Program is a type of investment program that provides clients with access to several money managers, or mutual fund asset allocation models, without incurring additional transaction costs, such as commissions. If you participate in SEI's wrap fee program, you will pay our firm an advisory fee in addition to the investment management fee paid to SEI. SEI's advisory fee includes SEI's money management fees, certain transaction costs, reporting, and custodial and administrative costs. The overall cost you will incur if you participate in SEI's wrap fee program may be higher or lower than you might incur by separately purchasing the types of securities available in the program. In general, we manage our clients' accounts in the wrap fee program on either a discretionary or non- discretionary basis. Wrap accounts are typically more frequently traded than non-wrap accounts and therefore you may see more short term trades than in a non-wrap account. We manage non-wrap fee accounts on either a discretionary or a non-discretionary basis, and, although we typically use a long- term strategy, even non-wrap accounts may occasionally include some short-term trading. A long-term investment strategy will typically involve investing in securities that are anticipated to grow in value over a relatively long period of time. On the other hand, a short-term investment strategy will typically involve purchasing and selling securities within a relatively short period of time based on these securities' short-term price fluctuations. If you participate in SEI's wrap fee program, SEI will provide you with SEI's separate Wrap Fee Program Brochure explaining the program and costs associated with the program. Types of Investments We offer advice on various types of securities, including but not limited to stocks, bonds, real estate, mutual funds, exchange traded funds (ETFs), and cash equivalent instruments. Portfolios are designed based on your investment objectives, risk tolerance, net worth, net income, and various other suitability factors. Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. 6  Financial Guidance At Lexington Financial Life Management, we believe that your wealth is certainly more than just your liquid assets. Our approach looks at all of your assets comprehensively to ensure that your investments are aligned with your goals. Our team of professionals work together to provide: Investment Consulting Insurance Consulting IT Support and Security • Collaboration and Coordination with Internal and External Advisors • Financial and Retirement Planning • Estate Planning • Trust Protector Services • Business Planning and Valuation • Business Audits • Bill Payment and Financial Reporting • Wellness • • • Asset Preservation • • Charitable Planning and Giving • Consolidated Wealth Reporting • Debt Structure Analysis and Negotiations • Retirement Plan Formation and Administration • Elder Care Consulting • Performance Analytics • Tax Planning and Preparation • Philanthropic Goal Setting and Solutions • Accounting and Tax Services There are three steps in the Financial Guidance Process: Implementation • Proposal for Development of Financial Life Strategy • • Management/Monitoring We offer financial guidance which typically involves providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. These services can range from broad-based financial guidance to consultative or single subject planning. If you retain our firm for financial guidance services, we will meet with you to gather information about your financial circumstances and objectives. We may also use various tools to determine your current financial position and to define and quantify your long-term goals and objectives. Once we specify those long-term objectives (both financial and non-financial), we will develop shorter-term, targeted objectives. Once we review and analyze the information you provide to our firm we will deliver a written strategy to you, designed to help you achieve your stated financial goals and objectives. Financial strategies are based on your financial situation at the time we present the strategy to you, and on the financial information you provide to us. You must promptly notify our firm if your financial situation, goals, objectives, or needs change. 7  IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from an ERISA account to an account that we manage or provide investment advice to, because the assets increase our Assets Under Management and, in turn, our advisory fees. In contrast, we receive less, or no, compensation if assets remain in the current plan or are rolled over to another Company's plan in which you may participate. Assets Under Management As of January 31, 2025 we provide continuous management services for $80,342,400 in client assets managed on a discretionary basis and $22,444,485 in client assets managed on a non-discretionary basis. We also provide advice on an additional (approximate) $200,000,000 in client assets that are not continuously managed and are therefore not considered to be regulatory assets under management. Item 5 Fees and Compensation Investment Consulting Fees Depending on the arrangements made at the inception of the engagement (or as amended thereafter) we may charge you either a fixed fee or a percentage calculated based on the market value of the assets in the account on the last day of the month, including any margin balances. We primarily charge our fee quarterly, in advance; however, we do have some legacy clients that are billed monthly in arrears or under a different fee schedule. In most cases, the calculation for Investment Consulting Services will be based upon a percentage of the market value of the assets and will range between 0.20% and 2.00%. Fees may be negotiated. A pro rata fee will be charged for any period less than a full billing cycle. In the event the Agreement is terminated during a calendar year, a pro-rata refund will be issued to the client for unearned fees. 8  Assets may be managed on a discretionary or a non-discretionary basis and may be considered either "assets under advisement" or "assets under management" depending on the nature of the engagement with the client. These assets are included in the assets that we base our fees on. Advisory fees charged by SEI are separate and apart from our advisory fees. Assets managed by SEI will be included in calculating our advisory fee. Advisory fees that you pay to SEI are established and payable in accordance with the brochure provided by SEI. These fees may or may not be negotiable. You should review SEI's brochure and take into consideration SEI's fees along with our fees to determine the total fees associated with this program. You will be required to sign an agreement directly with SEI. You may terminate your advisory relationship with the SEI according to the terms of the agreement with SEI. You should review SEI's disclosure brochure for specific information on how you may terminate your advisory relationship and how you may receive a refund, if applicable. Although we believe the combined advisory fee charged by our firm and SEI is competitive, comparable services may be obtained from other sources at a lower price. We will either invoice you directly for the advisory fees or we will deduct our fee directly from your account through the qualified custodian holding your assets. We will deduct our advisory fee only when the following requirements are met: • You provide our firm with written authorization permitting the fees to be paid directly from your account held by the qualified custodian. • The qualified custodian agrees to send you a statement, at least quarterly, indicating all amounts dispersed from your account including the amount of the advisory fee paid directly to our firm. The Advisory Services Agreement ("Agreement") is effective on the date indicated in the agreement. Unless otherwise noted in the Agreement, either party may terminate the Agreement at any time upon 30 days' written notice to the other party. Termination of the Agreement shall be considered as of the termination date detailed in the written notice. Financial Guidance There are three steps in the Financial Guidance Process and a fee for such services: Implementation • Proposal for Services/Development of Financial Life Strategy • • Management/Monitoring Proposal for Development of Financial/Life Strategy We may charge a one-time, flat fee for analysis and recommendations (Strategy) for achieving your goals. Flat fees generally range between $15,000 and $100,000 and are negotiated and agreed to in advance of any services rendered. Prior to engaging our firm for this service, you will be required to enter into a separate written agreement with us that sets forth the terms of the engagement, and specific fees to be paid. Generally, we require payment of one-half of the agreed upon fee upon entering into the agreement for services. The remaining balance is due and payable upon completion of the agreed upon services. In limited circumstances, the scope of the contracted services may change and exceed the agreed upon strategy. In such cases, you will be notified and we will request your prior approval before additional services are rendered and related fees assessed. You may terminate the agreement for services on written notice to our firm. You will incur a pro rata charge for services rendered prior to the termination of the agreement. 9  Implementation Fees Should you look to our firm to implement recommendations made as part of the Strategy development, we may charge additional fees to implement the clients' specific needs. Implementation fees generally range from $5,000 to $25,000. Prior to engaging our firm for this service, you will be required to enter into a separate written agreement with us that sets forth the terms of the engagement, and specific fees to be paid. Generally, we require payment of one-half of the agreed upon fee upon entering into the agreement for services. The remaining balance is due and payable upon completion of the agreed upon services. In limited circumstances, the scope of the contracted services may change and exceed the agreed upon strategy. In such cases, you will be notified and we will request your prior approval before additional services are rendered and related fees assessed. You may terminate the agreement for services on written notice to our firm. You will incur a pro rata charge for services rendered prior to the termination of the agreement. Management/Monitoring Lexington's fees to Manage/Monitor the Strategy are subject to negotiation based on factors such as the overall complexity of the Clients' financial situation, the number of entities, the nature and location of services provided, net worth, assets/liabilities and other factors unique to the specific client situation. Fees range from $30,000 to $200,000 annually depending upon the agreed scope of the work being provided. We primarily charge our fee quarterly, in advance; however, we do have some legacy clients that are billed monthly in arrears or under a different fee schedule. A pro rata fee will be charged for any period less than a full billing cycle. In the event the Agreement is terminated during a calendar year, a pro-rata refund will be issued to the client for unearned fees. Compensation for the Sale of Other Investment Products Some persons providing investment advice on behalf of our firm are licensed as independent insurance agents. These persons will earn commission-based compensation for selling insurance products, including insurance products they sell to you. Insurance commissions earned by these persons are separate and in addition to our advisory fees. This practice presents a conflict of interest because persons providing investment advice on behalf of our firm who are insurance agents have an incentive to recommend insurance products to you for the purpose of generating commissions rather than solely based on your needs. You are under no obligation, contractually or otherwise, to purchase insurance products through any person affiliated with our firm. Item 6 Performance-Based Fees and Side-By-Side Management We do not charge any performance-based fees. The fee charged as described above is not charged on the basis of a share of capital gains upon or capital appreciation of the funds or any portion of the funds of our advisory clients. Item 7 Types of Clients Our firm provides investment management consulting services to high net-worth and ultra-high net- worth individuals and families, pensions and profit sharing plans, trusts, estates, charitable organizations, corporations and other business entities. In general, we do not require a minimum dollar amount to open and maintain an advisory account; however, we have the right to terminate your account if it falls below a minimum size, which, in our sole opinion, is too small to effectively manage. 10  Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Our goals-based, family-centric life management methodology is significantly different from traditional portfolio management. Families often have multiple goals, time horizons, and required probabilities of success. Our methodology begins and ends with you at the center of every decision for portfolio implementation and management. Because we focus on your unique situation, we recognize that reaching your specific goal is more valuable than simply a comparison to industry benchmarks. Lexington strives to deliver a holistic approach to achieving your goals over time and building confidence as we move forward to the achievement of your success. By organizing your goals and assets around your life objectives, we help you see the big picture. We may use one or more of the following methods of analysis or investment strategies when providing investment advice to you: • Modern Portfolio Theory (MPT) - a theory of investment which attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, by carefully diversifying the proportions of various assets. • Risk: Market risk is that part of a security's risk that is common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. • Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. • Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long-term which may not be the case. There is also the risk that the segment of the market that you are invested in or perhaps just your particular investment will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short-term in other investments. • Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities' short-term price fluctuations. • Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short-term which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to log-term trading. There are many factors that can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a smaller impact over longer periods of times. • Short-term trading is not a fundamental part of our overall investment strategy, but we may use this strategy occasionally when we determine that it is in your best interest. This may include buying and selling securities frequently in an effort to capture significant market gains and avoid significant losses. However, there is a risk that frequent trading can negatively affect investment performance, particularly through increased brokerage and other transactional costs and taxes. 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 horizon, financial information, liquidity needs, and other various suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. 11  We recommend various types of securities and we do not primarily recommend one particular type of security over another since each client has different needs and different tolerance for risk. Each type of security has its own unique set of risks associated with it and it would not be possible to list here all of the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with the investment. Risk of Loss Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past performance is in no way an indication of future performance. Item 9 Disciplinary Information Neither Mr. Veitch nor Lexington Investment Consulting, LLC have any disclosable disciplinary matters that are required to be reported on this Disclosure Brochure. See also Investment Adviser Representative Public Disclosure report at www.adviserinfo.sec.gov. Item 10 Other Financial Industry Activities and Affiliations Some persons associated with our firm have an ownership interest (including voting rights) in Pendleton Square Holdings, LLC (formerly known as Rhino Holding Company, LLC). Pendleton Square Holdings, LLC, owns Pendleton Square Trust Company, a trust company that provides trust and estate administration services and legacy planning. Clients of our firm may be invested in Pendleton Square Holdings, LLC. Future clients will not be solicited to invest in Pendleton Square Holdings, LLC, however, we may refer clients that are in need of trust services to Pendleton Square Trust Company. This presents a conflict of interest since our associated persons may indirectly be compensated as a result of their ownership in Pendleton Square Holdings, LLC. You are under no obligation to use the services of Pendleton Square Trust Company. Some persons providing investment advice on behalf of our firm are licensed as insurance agents. These persons will earn commission-based compensation for selling insurance products, including insurance products they sell to you. Insurance commissions earned by these persons are separate from our advisory fees. Refer to the Fees and Compensation section above for more information on the compensation received by insurance agents who are affiliated with our firm. Lexington Financial Life Management, LLC the holding company for Lexington Investment Consulting, LLC (LIC) is developing a FinTech Platform named MyVFO, Inc. accredited investor clients of LIC have been solicited to, and will be making an investment in, MyVFO, Inc. via a SAFE Agreement (Simple Agreement for Future Equity) in order to assist with the development of the platform. This presents a conflict of interest in that we have a financial incentive to recommend the investment to those certain accredited investor clients. Clients are under no obligation to accept such a recommendation and we will only recommend this investment to clients we determine are suitable for it. We have an interest in a Private Equity Fund in which some of our clients are also invested. This creates a conflict of interest since we have an incentive to recommend that you continue to hold your interests in such Fund. To mitigate this conflict of interest, we have established policies and procedures to ensure that we comply with our fiduciary duty to provide impartial advice to our clients in their best interests. 12  Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Our firm has adopted a Code of Ethics, the full text of which is available to our clients and prospective clients upon request by contacting us at the telephone number on the cover page of this brochure. We have several goals in adopting this Code. First, our firm desires to comply with all applicable laws and regulations governing its practice, and our management has determined to set forth guidelines for professional standards, under which all associated persons of our firm are to conduct themselves. We have set high standards, the intention of which is to protect our client's interests at all times and to demonstrate our commitment to our fiduciary duties of honesty, good faith and fair dealing with our clients. All associated persons are expected to adhere strictly to these guidelines, as well as any procedures for approval and reporting established in the Code of Ethics primarily related to violations of the Code. In addition, our firm maintains and enforces written policies reasonably designed to prevent the misuse of material non-public information by our firm or any person associated with our firm. To help mitigate conflict of interest, it is our express policy that neither our firm nor our employees shall have priority in any purchase or sale over our clients' accounts. Our firm or individuals associated with the firm may buy or sell - for their personal account(s) - investment products identical to those recommended to clients. A conflict of interest exists in such cases because we have the ability to trade ahead of you and potentially receive more favorable prices than you will receive. (1)(2) Personal Trading Practices Our firm or persons associated with our firm may buy or sell the same securities that we recommend to you or securities in which you are already invested. A conflict of interest exists in such cases because we have the ability to trade ahead of you and potentially receive more favorable prices than you will receive. To mitigate this conflict of interest, it is our policy that neither our firm nor persons associated with our firm shall have priority over your account in the purchase or sale of securities. Participation or Interest in Client Transactions We have an interest in a Private Equity Fund in which some of our clients are also invested. This creates a conflict of interest since we have an incentive to recommend that you continue to hold your interests in such Fund. To mitigate this conflict of interest, we have established policies and procedures to ensure that we comply with our fiduciary duty to provide impartial advice to our clients in their best interests. (1) This investment policy has been established recognizing that some securities being considered for purchase and/or sale on behalf of Lexington Investment Consulting, LLC's clients trade in sufficiently broad markets to permit transactions by clients to be completed without an appreciable impact on the markets of the securities. Under certain circumstances, exceptions may be made to the policies stated above. Records of these trades, including the reasons for the exceptions, will be maintained with Lexington Investment Consulting, LLC's records in the manner set forth above. (2) The foregoing does not apply to certain types of securities, such as obligations of the U.S. Government, and shares in open-end mutual funds. Open-end mutual funds are purchased or redeemed at a fixed net asset value price per share specific to the date of purchase or redemption. As such, transactions in mutual funds by Advisory Representatives are not likely to have an impact on the prices of the fund shares in which clients invest. Item 12 Brokerage Practices SEI Programs 13  In order to be eligible for the SEI Programs, clients are required to use SEI Investment Distribution Co., an SEC-registered broker/dealer and FINRA member broker/dealer, for the placement of all trades. Therefore, through our recommendation of the SEI Programs, we are recommending SEI Investment Distribution Co. as the broker/dealer to be used. As we will not request the discretionary authority to determine the broker/dealer to be used or the commission rates to be paid in these situations, you must direct us to utilize SEI Investment Distribution Co. In directing the use of a particular broker or dealer, it should be understood that we will not have authority to negotiate commissions among various brokers or obtain volume discounts, and best execution may not be achieved. Not all investment advisers require clients to direct the use of specific brokers. We may use other custodians from time to time as we deem appropriate and consistent with our duty of best execution. All such broker dealers/custodians are unaffiliated and offer independent investment advisors services, which include custody of client securities, trade execution, clearance and settlement of transactions, and daily research and investment information. Item 13 Review of Accounts For clients that participate in our investment consulting services, your assigned Investment Consultant will review your account at least quarterly and provide written, quarterly performance reports. Additional reviews may be conducted based on various circumstances, including, but not limited to, contributions or withdrawals, year-end tax planning, or changes in risk/return objectives. At your request, portfolio reviews can be done less frequently than quarterly but not less than annually. Additional written reports are prepared at our discretion. In addition, you will receive trade confirmations, monthly or quarterly statements, and year-end tax statements from your account custodian(s). One-time, flat fee arrangements or non-fee based accounts do not receive periodic reviews or quarterly written reports. Item 14 Client Referrals and Other Compensation Currently, we do not compensate any solicitors (individual or entity) for client referrals. However, we may enter into such arrangements in the future. In such cases, any employee or non-employee (outside) solicitors, e.g. unaffiliated broker/dealers, investment advisors, accountants, attorneys, etc., who are directly responsible for bringing a client to our firm, may receive compensation from us for the client referral. Under these arrangements, you do not pay higher fees than our normal/typical advisory fees. Such arrangements will comply with the requirements set forth under the Investment Advisers Act of 1940 and/or the applicable state securities acts, including the requirement for a written agreement between our firm and the solicitor. Non-employee solicitors must provide a copy of our firm's ADV Part 2 (Disclosure Brochure) and a separate solicitor's disclosure statement regarding the relationship between the solicitor and our firm to the prospective client at the time of the solicitation or referral. The client will be requested to acknowledge this arrangement prior to acceptance of the client's account for advisory services. Applicable state laws may require solicitors to become either licensed or registered as representatives of our firm or as an independent investment advisor. 14  Item 15 Custody You should receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains your investment assets. We urge you to carefully review such statements and compare such official custodial records to the account statements that we may provide to you. Our statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. As paying agent for our firm, your independent custodian will directly debit your account(s) for the payment of our advisory fees. This ability to deduct our advisory fees from your accounts causes our firm to exercise limited custody over your funds or securities. We do not have physical custody of any of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other independent qualified custodian. Investment In Affiliated Company MyVFO, Inc. is 100% owned by LIC's holding company, Lexington Financial Life Management, LLC. MyVFO, Inc. is developing a WealthTech Platform and accredited investor clients of LIC have been solicited to, and are making, investments therein to assist with its development. This presents a conflict of interest since we have a financial incentive to recommend the investment. Clients are under no obligation to accept such a recommendation and we will only recommend this investment to clients we determine are suitable for it. In light of LFLM's common control and ownership of both LIC and MyVFO, Inc. we will have access to the funds deposited by LIC clients into MyVFO's bank account and therefore are considered to have custody over such funds. In accordance with the Custody Rule, therefore, we will have a surprise annual audit performed of those investments by an unaffiliated accounting firm. We will provide each investor in MyVFO, Inc. with audited annual financial statements. If you are an investor and have questions regarding the financial statements or if you did not receive a copy, contact us directly at the telephone number on the cover page of this brochure. Trustee Services Dale Veitch, of Lexington Investment Consulting, LLC, serves as trustee to certain Asset Protection Trusts, the beneficiaries of which are clients of our firm and for whom we provide investment advisory services. However, Mr. Veitch's capacity as trustee does not give our firm custody over the clients' assets since the nature of the trusts does not allow him to access any of the bank or custodial accounts of the Trusts. These accounts will be held with a bank, broker-dealer, or other qualified custodian. You should carefully review account statements for accuracy. Item 16 Investment Discretion Our firm usually receives discretionary authority from you through the investment consulting agreement and SEI's account application forms at the outset of our advisory relationship. This grant of discretion applies to the authority to determine the securities, and the amount of securities to be bought or sold, without obtaining your consent or approval prior to each transaction. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for your account. Our firm observes the investment policies, limitations, and restrictions of our advisory clients when selecting securities and determining the amounts of securities to buy or sell. Your investment guidelines and restrictions must be provided to our firm in writing. 15  If you enter into non-discretionary arrangements with our firm, we will obtain your approval prior to the execution of any transactions for your account(s). You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis. Item 17 Voting Client Securities As a matter of firm policy and practice, we do not vote proxies on behalf of our advisory clients. You will receive your proxies or other solicitations directly from your custodian or transfer agent. You retain the responsibility for voting proxies for any and all securities maintained in your portfolios. At your request, our firm may provide advice to you regarding the voting of proxies. The final decision of how to vote the proxy rests with the client. Item 18 Financial Information We are not required to provide financial information to our clients because we: • Do not have financial commitment that impairs our ability to meet contractual and fiduciary commitments to our clients; • Have not been the subject of a bankruptcy proceeding; and • Do not require prepayment of more than $1,200 in fees six months or more in advance. Item 19 Requirements for State Registered Advisers We are a federally registered investment adviser; therefore, we are not required to respond to this item. Item 20 Additional Information Privacy Policy Associated persons may come in contact with confidential information concerning our firm and our clients. "Confidential information" generally means all information not publicly available (through the media or public records) and includes, but is not limited to: • The composition of our client portfolios. • Certain records, procedures and other proprietary information. • Family and personal information. It is our firm's policy that individuals employed by the firm must not disclose, directly or indirectly, any confidential information to anyone other than firm personnel and authorized professional advisors such as broker dealers, attorneys, and accountants who need such information in order to discharge their professional services. We view protecting your private information as a top priority. Pursuant to applicable privacy requirements, we have instituted policies and procedures to ensure that we keep your personal information private and secure. 16  We do not disclose any non-public personal information about you to any unaffiliated third parties, except as permitted by law. We rely on certain third parties for services that enable us to provide our advisory services to you, such as transfer agents, custodians, accountants, attorneys, auditors or other consultants, we may share non-public personal information with such unaffiliated third parties. We restrict internal access to non-public personal information about you to employees who need that information in order to provide products or services to you. We maintain physical and procedural safeguards that comply with regulatory standards to guard your non-public personal information and to ensure our integrity and confidentiality. We will not sell information about you or your accounts to anyone. We do not share your information unless it is required to process a transaction, at your request, or required by law. You will receive a copy of our privacy notice prior to or at the time you sign an advisory agreement with our firm. Thereafter, we will deliver a copy of the current privacy policy notice to you on an annual basis. Contact our main office at the telephone number on the cover page of this brochure if you have any questions regarding this policy. Class Action Lawsuits We do not determine if securities held by you are the subject of a class action lawsuit or whether you are eligible to participate in class action settlements or litigation nor do we initiate or participate in litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or negligence by issuers of securities held by you. Trade Errors In the event a trading error occurs in your account, our policy is to restore your account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. 17