Overview

Headquarters
Cardiff, CA
Total Firm Assets
$121 million
Average High-Net-Worth Client Portfolio Size
$2.4 million

Fee Structure

Primary Fee Schedule (LIFE STRATEGIES, INC)

MinMaxMarginal Fee Rate
$0 $250,000 1.45%
$250,001 $500,000 1.20%
$500,001 $1,000,000 0.90%
$1,000,001 and above 0.65%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $11,125 1.11%
$5 million $37,125 0.74%
$10 million $69,625 0.70%
$50 million $329,625 0.66%
$100 million $654,625 0.65%

Clients

High-Net-Worth Share of Firm Assets
53.00%
Number of High-Net-Worth Clients
27
Total Client Accounts
269
Discretionary Accounts
269

Services Offered

Services: Financial Planning, Portfolio Management for Individuals

Regulatory Filings

SEC CRD Number
167732

Primary Brochure: LIFE STRATEGIES, INC (2026-08-21)

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Life Strategies, Inc. Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Life Strategies, Inc. If you have any questions about the contents of this brochure, please contact us at (916) 541-3846 or by email at:danderson@febcinc.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 Life Strategies, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. Life Strategies, Inc.’s CRD number is: 167732. 2533 S Coast Hwy 101, Suite 280 Cardiff, CA 92007 (916) 541-3846 danderson@febcinc.com Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 08/21/2026 i Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of Life Strategies, Inc. on 01/12/2026 are described below. Material changes relate to Life Strategies, Inc.'s policies, practices or conflicts of interests only. • Life Strategies, Inc. updated its primary office address (Cover Page). ii Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ....................................................................................................................................... ii Item 3: Table of Contents ...................................................................................................................................... iii Item 4: Advisory Business ......................................................................................................................................2 Item 5: Fees and Compensation .............................................................................................................................4 Item 6: Performance-Based Fees and Side-By-Side Management ....................................................................6 Item 7: Types of Clients ..........................................................................................................................................6 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ...............................................................7 Item 9: Disciplinary Information ...........................................................................................................................9 Item 10: Other Financial Industry Activities and Affiliations .........................................................................10 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...............11 Item 12: Brokerage Practices ................................................................................................................................12 Item 13: Review of Accounts ................................................................................................................................13 Item 14: Client Referrals and Other Compensation ..........................................................................................14 Item 15: Custody ....................................................................................................................................................15 Item 16: Investment Discretion ............................................................................................................................15 Item 17: Voting Client Securities (Proxy Voting) ..............................................................................................15 Item 18: Financial Information .............................................................................................................................15 iii Item 4: Advisory Business A. Description of the Advisory Firm Life Strategies, Inc. (hereinafter “LSI”) is a corporation organized in the State of California. The firm was formed in February 2009, and the principal owner is Douglas Anderson. 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) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. 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. LSI will require discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. 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 debit/credit planning. 2 Services Limited to Specific Types of Investments LSI generally limits its investment advice to mutual funds, fixed income securities, insurance products including annuities, equities and ETFs, although LSI primarily recommends long term, buy and hold of equities, ETFs, and mutual funds. LSI may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status 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. C. Client Tailored Services and Client Imposed Restrictions LSI will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by LSI on behalf of the client. LSI may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. Budget and cash-flow analysis create a time-horizon based portfolio mix. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. LSI does not participate in wrap fee programs. 3 E. Assets Under Management LSI has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 121,245,786 $0 December 2025 Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees $0 - $250,000 1.45% $250,001 - $500,000 1.20% $500,001 - $1,000,000 0.90% $1,000,001 - AND UP 0.65% LSI uses an average of the daily balance in the client's account throughout the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. The final fee schedule will be memorialized in the client’s advisory agreement. 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 generally with 5 days' written notice. Financial Planning Fees Fixed Fees The negotiated fixed rate for creating client financial plans is between $500 and $3,000. 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. 4 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 arrears. Payment of Financial Planning Fees Financial planning fees are paid via check. Fixed financial planning fees are paid 100% in advance, but never more than six months in advance. C. Client Responsibility for Third Party Fees Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by LSI. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees LSI collects certain fees in advance and certain fees in arrears, as indicated above. Refunds for fees paid in advance but not yet earned will be refunded on a prorated basis and returned within fourteen days to the client via check, or return deposit back into the client’s account. Fixed fees that are collected in advance will be refunded based on the prorated amount of work completed at the point of termination. E. Outside Compensation for the Sale of Securities to Clients Douglas Scott Anderson is an insurance agent and, in this role, accepts compensation for the sale of investment products to LSI clients. 1. 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 5 supervised persons receive compensation, LSI will document the conflict of interest in the client file and inform the client of the conflict of interest. 2. 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. 3. Commissions are not LSI's primary source of compensation for advisory services Commissions are not LSI’s primary source of compensation for advisory services. 4. 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. Item 7: Types of Clients LSI generally provides advisory services to the following types of clients: ❖ ❖ Individuals High-Net-Worth Individuals There is no account minimum for any of LSI’s services. 6 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 Fundamental analysis. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Investment Strategies LSI uses long 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 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. 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. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 7 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 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 risk of losing share price value, albeit rather minimal. 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. Risks in investing in ETFs include trading risks, liquidity and shutdown risks, risks associated with a change in authorized participants and non-participation of authorized participants, risks that trading price differs from indicative net asset value (iNAV), or price fluctuation and disassociation from the index being tracked. With regard to trading risks, regular trading adds cost to your portfolio thus counteracting the low fees that one of the typical benefits of ETFs. Additionally, regular trading to beneficially “time the market” is difficult to achieve. Even paid fund managers struggle to do this every year, with the majority failing to beat the relevant indexes. With regard to liquidity and shutdown risks, not all ETFs have the same level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading conditions are more accurately reflected in implied liquidity rather than the average daily volume of the ETF itself. Implied liquidity is a measure of what can potentially be traded in ETFs based on its underlying assets. ETFs are subject to market volatility and the risks 8 of their underlying securities, which may include the risks associated with investing in smaller companies, foreign securities, commodities, and fixed income investments (as applicable). Foreign securities in particular are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets. ETFs that target a small universe of securities, such as a specific region or market sector, are generally subject to greater market volatility, as well as to the specific risks associated with that sector, region, or other focus. ETFs that use derivatives, leverage, or complex investment strategies are subject to additional risks. The return of an index ETF is usually different from that of the index it tracks because of fees, expenses, and tracking error. An ETF may trade at a premium or discount to its net asset value (NAV) (or indicative value in the case of exchange-traded notes). The degree of liquidity can vary significantly from one ETF to another and losses may be magnified if no liquid market exists for the ETF’s shares when attempting to sell them. Each ETF has a unique risk profile, detailed in its prospectus, offering circular, or similar material, which should be considered carefully when making investment decisions. Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet requirement or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. 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. 9 Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither LSI nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither LSI nor its representatives 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 Douglas Scott Anderson is an independent licensed insurance agent. This activity creates a conflict of interest since there is an incentive to recommend insurance products based on commissions or other benefits received from the insurance company, rather than on the client’s needs. Additionally, the offer and sale of insurance products by supervised persons of LSI are not made in their capacity as a fiduciary, and products are limited to only those offered by certain insurance providers. LSI addresses this conflict of interest by requiring its supervised persons to act in the best interest of the client at all times, including when acting as an insurance agent. LSI periodically reviews recommendations by its supervised persons to assess whether they are based on an objective evaluation of each client’s risk profile and investment objectives rather than on the receipt of any commissions or other benefits. LSI will disclose in advance how it or its supervised persons are compensated and will disclose conflicts of interest involving any advice or service provided. At no time will there be tying between business practices and/or services (a condition where a client or prospective client would be required to accept one product or service conditioned upon the selection of a second, distinctive tied product or service). No client is ever under any obligation to purchase any insurance product. Insurance products recommended by LSI’s supervised persons may also be available from other providers on more favorable terms, and clients can purchase insurance products recommended through other unaffiliated insurance agencies. 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. 10 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. 11 Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers 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 market expertise and research access provided by 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 require clients to use Schwab Institutional, a division of Charles Schwab & Co., Inc. 1. 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. 2. 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. 3. Clients Directing Which Broker/Dealer/Custodian to Use LSI will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. 12 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 Quarterly by Douglas Anderson, President, 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 Douglas Anderson, President. 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. LSI will also provide at least quarterly a separate written statement to the client. Each financial planning client will receive the financial plan upon completion. 13 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 does not receive any economic benefit, directly or indirectly from any third party for advice rendered to LSI's clients. With respect to Schwab, LSI receives access to Schwab’s institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Schwab Advisor Services. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For LSI client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab also makes available to LSI other products and services that benefit LSI but may not benefit its clients’ accounts. These benefits may include national, regional or LSI specific educational events organized and/or sponsored by Schwab Advisor Services. Other potential benefits may include occasional business entertainment of personnel of LSI by Schwab Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist LSI in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of LSI’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of LSI’s accounts. Schwab Advisor Services also makes available to LSI other services intended to help LSI manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, Schwab may make available, arrange and/or pay vendors for these types of services rendered to LSI by independent third parties. Schwab Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third- 14 party providing these services to LSI. LSI is independently owned and operated and not affiliated with Schwab. 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. 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 provides discretionary investment advisory services to clients. The advisory contract established with each client sets forth 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 when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. In some instances, LSI’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to LSI. 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. 15 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. 16

Frequently Asked Questions