Overview
- Headquarters
- Fort Washington, PA
- Total Firm Assets
- $22.0 billion
- Average High-Net-Worth Client Portfolio Size
- $0.9 million
- Minimum Account Size
- $10,000
Fee Structure
Primary Fee Schedule (LINCOLN INVESTMENT PLANNING, LLC FORM ADV PART 2A BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | and above | 1.25% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $12,500 | 1.25% |
| $5 million | $62,500 | 1.25% |
| $10 million | $125,000 | 1.25% |
| $50 million | $625,000 | 1.25% |
| $100 million | $1,250,000 | 1.25% |
Clients
- High-Net-Worth Share of Firm Assets
- 19.56%
- Number of High-Net-Worth Clients
- 4,604
- Total Client Accounts
- 199,383
- Discretionary Accounts
- 103,177
- Non-Discretionary Accounts
- 96,206
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Investment Advisor Selection
Regulatory Filings
- SEC CRD Number
- 519
Additional Brochure: LINCOLN INVESTMENT PLANNING, LLC FORM ADV PART 2A APPENDIX I BROCHURE (2026-03-31)
View Document Text
Item 1: Cover Page Form ADV Part 2A Appendix I
Lincoln Investment Planning, LLC
Wrap Fee Program Brochure
As of March 31, 2026
Principal Office:
601 Office Center Drive, Suite 300
Fort Washington, PA 19034
(800) 242-1421
You may also visit us on the web at www.lincolninvestment.com.
This Wrap Fee Program Brochure provides information about the qualifications and business practices of Lincoln
Investment Planning, LLC, a registered investment adviser with the U.S. Securities and Exchange Commission
(SEC). If you have any questions about the contents of this brochure, please contact us at (800) 242-1421. The
information in this brochure has not been approved or verified by the SEC or by any state securities authority.
Furthermore, registration with the SEC does not imply a certain level of skill or training.
Additional information about Lincoln Investment Planning, LLC is also available on the SEC's website at
www.adviserinfo.sec.gov.
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Item 2: Material Changes
This section provides us the opportunity to highlight for you the material changes to our Lincoln Investment
Planning, LLC Form ADV 2A and Form 2A Appendix I since our last annual amendment in March 2025.
This information is being provided so that you can continue to make informed decisions about the advisory services
provided to you by Lincoln Investment Planning, LLC.
The following is provided as an update to Lincoln Investment’s Form ADV 2A Item 5, Fees and
Compensation and Form ADV 2A Appendix I Item 4, Services, Fees and Compensation:
Other Compensation to Lincoln Investment and Our Conflicts of Interest
Lincoln Investment recognizes its fiduciary responsibility to place your interests above ours and that other
compensation received by us, or an affiliate, from other sources presents a conflict of interest and could be looked
upon by you as an incentive for us to recommend investment products or advisory services based on compensation
rather than on your financial needs. Below is a description of conflicts of interest that we have identified in the
conduct of our business that we believe may be material. With many of these conflicts, we have taken steps to
mitigate or reduce the conflict.
Understanding Share Classes in Lincoln Investment Advisory Accounts
Mutual funds are common investments for individuals. A mutual fund pools money from many investors and invests
the money in securities or other assets. A mutual fund has various expenses that are paid from fund assets. These
internal expenses are reflected in the fund's "expense ratio." Such expenses include fees paid to the adviser that
manages the fund, operational expenses, and fees paid to the brokers that sell shares of, and provide services to, the
fund. These are ongoing fees and expenses charged throughout the life of the mutual fund investment. Fees and
expenses are an important consideration in selecting a mutual fund because these charges lower an investor's returns.
A mutual fund frequently offers investors different "share classes." Each class will invest in the same "pool" or
portfolio of securities and other assets, but each class will have different fees and expenses and, therefore, different
returns. For example, some share classes have higher expense ratios because they pay brokers more for selling or
servicing that particular share class. In contrast, other share classes of the same fund may have lower internal fees
and expenses. A single mutual fund will often have share classes with different expense ratios, with the share classes
that have higher expense ratios generally having lower returns than share classes with lower expense ratios. In other
words, an individual investor may pay more, or less, for precisely the same mutual fund investment, depending on
the share class. These internal fees and expenses are in addition to any fees a broker may directly charge customers
on particular share classes, including transaction-related fees, such as surcharge fees, at the time of buying or selling
the fund shares, and are in addition to the investment advisory fee you will pay.
The expense ratio of a fund is disclosed in the fund’s prospectus and annual reports and generally reflects the annual
operating costs of the fund, assessed as a percentage of a fund’s average assets. The expense ratio within a mutual
fund share class can fluctuate from what is shown in a prospectus for the fund offering and annual report and can
vary over time and from year to year. A fund that was deemed to have a lower expense ratio at the time of purchase
may not actually maintain that expense ratio during the time that the fund is held and new fund share classes may
become available with different expense ratios.
Lincoln Investment looks at the “Prospectus Net Expense Ratio” as provided by a third-party data provider for each
mutual fund share class to determine the least expensive eligible share class. The Prospectus Net Expense Ratio is a
fund’s stated total annual operating expense percentage after any contractual fee waivers or other expense
reimbursements to the fund.
Lincoln Investment’s Share Class Selection Policy for Advisory Accounts
This share class selection policy applies to your advisory assets that are custodied at Pershing LLC (“Pershing”) and
for which Lincoln Investment and/or your financial professional initiate the trade and is described below. For your
advisory assets custodied at Pershing utilizing an overlay manager, the share class designated by Lincoln Investment
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is subject to the approval of your overlay manager. The overlay manager can choose to utilize a share class in your
account that differs from the policy outlined below. If applicable, please see your overlay manager’s Form ADV 2A
and/or Appendix I for additional details.
Although you are purchasing at net asset value of the fund, there are internal expenses built into every mutual fund
that can impact the performance of your investment over time. Regardless of whether you have selected a
discretionary or non-discretionary advisory program, share class selection for your mutual fund purchases within
your advisory account will be determined by Lincoln Investment. Share class expenses can vary across different
share classes of the same fund. In furtherance of its fiduciary duty to advisory clients, Lincoln Investment will seek
to select the least expensive share class available on the applicable custodial platform for the selected mutual fund
for which all of our retail advisory accounts will be eligible (except that money market mutual funds within the
Sweep Program and 403(b)7/457(b) accounts are treated differently, each as described below). For purposes of this
policy, the least expensive share class is defined as the share class of a mutual fund that has the lowest prospectus
net expense ratio as published by the third-party data provider (or a share class with a net expense ratio that is no
greater than ten basis points (0.10%) different than such share class with the lowest net expense ratio), subject to the
share classes’ investment minimums being appropriate for all of our retail advisory investors, obtaining investment
minimum waivers where they are available, and selecting a share class that is available to all investors regardless of
account tax type. In addition, due to specific mutual fund company constraints, situations will arise where Lincoln
Investment chooses a share class that does not have the lowest prospectus net expense ratio in that mutual fund in
order to remain consistent with the share classes of other mutual funds within a particular fund family available on
our platform.
Accounts on the Lincoln Workplace Retirement Solutions platform for 403(b)/457 accounts custodied at Pershing in
the Client Custom Portfolios (advisor-managed) program are subject to a No Surcharge Fund First (“NSFF”) policy,
as described below. The No Surcharge Fund First (“NSFF”) policy is applicable to Client Custom Portfolios
(advisor-managed) 403(b)/457(b) accounts only. Under the NSFF policy, for fund families that offer certain share
classes that assess a surcharge, Lincoln Investment will make available the share class with the least expensive
internal expense ratio that does not assess a surcharge fee. If the fund family does not offer a share class without a
surcharge fee, Lincoln Investment will make available the share class with the least expensive internal expense ratio
and the surcharge fee will be assessed. Generally, and subject to additional conditions, the designated share class
will be ascertained by designating the share class with the lowest internal expense ratio for which no surcharge fee
applies and all 403(b)/457(b) accounts on the Pershing platform will be eligible. Where all share classes of a mutual
fund assess a surcharge fee, that surcharge fee fund will remain available subject to the surcharge fee discussed
above and in the Lincoln Investment Trading Fees, Account Service Fees and Disclosures – Accounts Held on
Pershing Platform.
In addition to the share class selection factors described above, Lincoln Investment will also consider various other
factors when considering share class conversions in your advisory accounts, including but not limited to, whether
the fund will allow tax-free conversions, as well as whether there is a ten basis point (0.10%) or greater difference in
the expense ratio between the existing share class and the new, proposed share class. The fund share class used in a
discretionary Lincoln Investment Managed Model Portfolio can be different than the fund share class used in other
Lincoln Investment advisory accounts, including accounts managed by your financial professional, as a fund
minimum waiver may be available for discretionary Lincoln Investment managed model portfolios but not for other
types of advisory accounts, such as accounts managed by your financial professional. Most mutual funds offer
varying share classes, but all custodians may not make all share classes of a mutual fund available; therefore, the
designated share class selected by Lincoln Investment will likely vary across custodial platforms.
If the fund and share class selected includes a 12b-1 fee, Lincoln Investment will continue to credit back to your
advisory account any 12b-1 fee revenue received by the firm on behalf of your advisory assets to eliminate the
conflict of interest associated with the receipt of such revenue.
Lincoln Investment will review available mutual fund share classes periodically to identify share classes that must
be changed in order to align with this policy. If a different share class is identified that meets our policy criteria as
described herein, Lincoln Investment will initiate a share class conversion for all mutual fund investments in those
share classes. In addition, for accounts subject to the NSFF policy, if it is determined that a mutual fund share class
that does not assess a surcharge fee is available and meets our policy criteria as described above, Lincoln Investment
will initiate a share class conversion for all mutual fund investments in the surcharge fee share class to that no
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surcharge fee share class (except that money market mutual funds within the Sweep Program are treated differently,
as described below). Share class conversions will appear on your account statements. The ability and length of time
to affect a share class conversion will vary and is subject to prospectus requirements and custodial platform
approval. If you transfer-in shares of a mutual fund into an advisory account that are in a share class with a lower
internal expense ratio than the share class available in your advisory program, Lincoln Investment can convert your
mutual fund position to the share class of that fund that meets our policy criteria as described herein (including a
share class with a higher internal expense ratio). Lincoln Investment can also restrict additional purchases of a share
class and convert any grandfathered share class during a periodic review. For accounts subject to the NSFF policy, if
you transfer-in shares of a mutual fund that assesses a surcharge fee, Lincoln Investment will convert your mutual
fund position from a mutual fund share class that assesses a surcharge fee to a share class that does not assess a
surcharge fee, if available.
Not all mutual funds and share classes available to the investing public will be available to Lincoln Investment
and/or available for use in your advisory program. You should not assume that you are or will be invested in the
least expensive share class available, and the share class of a mutual fund offered by Lincoln Investment can have
higher expenses, and therefore lower returns. Additionally, Lincoln Investment has selected a higher-cost share class
with respect to the Dreyfus Government Cash Management Fund – Service Shares Sweep Product, which is the
designated sweep product for non-ERISA 403(b)7 and 457(b) plans and participant accounts and the designated
secondary sweep product for excess balances in the Dreyfus Insured Deposits L Sweep Product. There are less
expensive share classes of the same money market mutual fund available that would not provide revenue sharing
with the firm or would provide lesser amounts of revenue sharing with the firm.
Information about the mutual funds and share classes that are available through your account, including their
investment policies, restrictions, charges and expenses, is contained in the mutual funds’ prospectuses. You should
read these prospectuses carefully.
Third-Party Payments to Lincoln Investment
Third-Party Payments and Revenue Sharing from Pershing
In our role as introducing broker-dealer for assets held at Pershing, Pershing provides credits, payments and benefits,
including but not limited to fee and expense reductions, that incentivize us to recommend and continue to use
Pershing as clearing firm and custodian and achieve agreed upon asset levels in The Bank of New York Mellon
Corporation (“BNY”)’s affiliated products and services. Pershing and BNY Mellon Advisors, Inc. (“BNYMA”) are
affiliates of BNY.
Pershing Revenue Sharing, Payments and/or Expense Credits with Lincoln Investment. For accounts held
on Pershing’s platform, Pershing provides certain credits and payments to Lincoln Investment, as introducing
broker-dealer, pursuant to a written agreement in consideration of the extension and/or continuation of Lincoln
Investment’s current agreement with Pershing. Lincoln Investment does not refund or offset these
credits/payments against fees paid by clients. This revenue does not vary with respect to the investment
choices/recommendations made in your Pershing account. Overall, the expense credits received by Lincoln
Investment from Pershing for 2025 as allocated to the firm and its affiliates represented less than one percent of
Lincoln Investment’s total advisory revenue, less than one percent of Capital Analysts’ revenue and less than one
percent of Lincoln Investment’s broker-dealer revenue. The receipt of these expense credits and payments create
a conflict of interest to Lincoln Investment to recommend and/or use Pershing as a custodian over other
custodians that do not share these fees, do not provide expense credits/payments to us or that would share lesser
amounts with us. Additionally, under our agreement with Pershing, there is a termination fee schedule with
amounts that decrease over time. Therefore, Lincoln Investment has an incentive to maintain the relationship
with Pershing for a longer period of time. We mitigate these conflicts by disclosing them to you and by not
sharing the credits/payments with your Advisor.
Pershing Margin Participation. For advisory and brokerage accounts held on Pershing’s platform, Lincoln
Investment, as introducing broker-dealer, marks up the base interest rate pursuant to a written agreement with
Pershing, resulting in a higher margin interest rate to you. This mark-up will not exceed 2.25% above the base
interest rate. The receipt of revenue sharing with Pershing creates a conflict of interest to Lincoln Investment to
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use Pershing as custodian over other custodians that do not permit us to mark-up the fees or limit the amount.
Lincoln Investment mitigates this conflict by disclosing it to you and by not sharing it with your Advisor.
Pershing Non-Purpose Loan Markups. For advisory and brokerage accounts held on Pershing’s platform,
Lincoln Investment, as introducing broker-dealer, marks up the base interest rate pursuant to a written agreement
with Pershing, resulting in a higher non-purpose loan interest rate to you. This mark-up will not exceed 0.75%
above the base interest rate. The receipt of revenue sharing with Pershing creates a conflict of interest to Lincoln
Investment to use Pershing as custodian over other custodians that do not permit us to mark-up the fees or limit
the amount. Lincoln Investment mitigates this conflict by disclosing it to you and by not sharing it with your
Advisor.
Trading and Account Service Fees. Lincoln Investment establishes brokerage commission schedules for its
advisory and brokerage accounts. For accounts held on Pershing’s platform for which Lincoln Investment is
introducing broker-dealer (i) Pershing charges trading and account service fees for which Lincoln Investment, as
introducing broker-dealer, has added a mark-up that ranges from 0% to 420%; (ii) For certain trading and
account services for which Pershing does not assess a fee to Lincoln investment, Pershing permits Lincoln
Investment, as introducing broker-dealer, to impose its own fee which is charged to you. The receipt of these
fees creates a conflict of interest for Lincoln Investment since it creates an incentive for Lincoln Investment to
continue to use Pershing as custodian over other custodians that do not permit us to mark-up the trading and
account service fees or would limit the amount, or that would not permit us to set our own fee. We mitigate these
conflicts by disclosing them to you and by not sharing the mark-ups and Lincoln Investment fees with your
Advisor. Your Advisor is permitted to pay certain fees on your behalf in their sole discretion.
Growth Incentive Credits/Payments. For accounts opened and/or assets moved to Pershing by Lincoln
Investment or its affiliate, Capital Analysts, Pershing provides a credit/payment to Lincoln Investment based on
the total asset value of such accounts when the accounts are opened on Pershing, or accounts/assets are moved to
Pershing or retained by Pershing, pursuant to a written agreement with Pershing. The receipt of these
credits/payments creates a conflict of interest to Lincoln Investment and its affiliate, Capital Analysts, to
recommend and/or use Pershing as a custodian over other custodians that do not share these fees, do not provide
credits/payments to us or that would share lesser amounts with us. This revenue is not shared with your Advisor.
Acquisition Financial Support Credits/Payments. For accounts acquired from other firms by Lincoln
Investment or its affiliate, Capital Analysts, Pershing provides a credit/payment to Lincoln Investment based on
the total asset value of such accounts when they will be moved to Pershing or retained by Pershing, pursuant to a
written agreement with Pershing. The credit/payment provided to Lincoln Investment is greater for acquired
accounts that will be moved to Pershing compared to the credit for acquired accounts that will be retained by
Pershing (accounts already existing on Pershing’s platform). The receipt of these credits/payments creates a
conflict of interest to Lincoln Investment and its affiliate, Capital Analysts, to recommend and/or use Pershing as
a custodian over other custodians that do not share these fees, do not provide credits/payments to us or that
would share lesser amounts with us. This revenue is not shared with your Advisor.
The Lincoln Investment Companies Sweep Program. The Lincoln Investment Companies offer a sweep
program (“Sweep Program”) under which uninvested cash or “free credit balances” in your eligible accounts that
are custodied with Pershing are automatically invested or deposited (“swept”) into money market mutual fund(s)
(“Money Fund Sweep Products”), or bank deposit sweep product(s) eligible for FDIC insurance protection up to
$2.5 million (“Bank Deposit Sweep Products”) (collectively referred to as “Sweep Product(s)”), which consist of
interest-bearing bank deposit accounts (“Deposit Accounts”) at Federal Deposit Insurance Corporation (“FDIC”)
member banks. The member banks (“Program Banks”) can include The Bank of New York Mellon (“BNY”) and
BNY Mellon, N.A., banking affiliates of Pershing or other banking affiliates of Pershing. When participating in
the Sweep Program, you appoint Pershing as your authorized agent to establish and maintain Deposit Accounts
at various Program Banks. The Bank Deposit Sweep Products and Money Fund Sweep Products are supported
and operated through a private labelling arrangement with Dreyfus, a division of Mellon Investments
Corporation (“MIC”) and are available only to clients of broker-dealers who clear through Pershing, such as
Lincoln Investment. Pershing has appointed a third-party service provider IntraFi Network LLC (“IntraFi” or
“Administrator”), BNY Mellon Securities Corporation (“BNYSC”) and Dreyfus to provide certain services with
respect to the operation of the Deposit Accounts. MIC is a registered investment adviser and BNYSC is a broker-
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dealer. BNY Mellon Investment Adviser, Inc. (“BNYIA” or “Adviser”) acts as investment adviser for the
Dreyfus Money Fund Sweep Products. Affiliates of BNY include but are not limited to, Pershing, BNYSC, MIC,
BNYIA, and BNY Mellon, N.A. BNY Mellon is the corporate brand for The Bank of New York Mellon
Corporation. For the most up-to-date information, see the applicable product-specific disclosure for a list of
BNY Mellon affiliates and their role in the operation of the Sweep Products.
Depending upon your account type, Lincoln Investment will designate a Sweep Product for use in your account.
Lincoln Investment offers two Bank Deposit Sweep Programs, the Dreyfus Insured Deposits L (“Tiered Rate
Sweep Product”) and the Dreyfus Insured Deposits LV (“Level Fee Sweep Product”), and two Money Fund
Sweep Products, the Dreyfus Government Cash Management Fund Service Shares Sweep Product (Ticker
symbol DGUXX) and the Dreyfus Government Cash Management Fund Investor Shares Sweep Product (Ticker
symbol DGVXX). Each of these Sweep Products except for the Dreyfus Government Cash Management Fund
Investor Shares, offered only to ERISA accounts and as the secondary Sweep Product for balances over
$2,490,000 in the Level Fee Sweep Product, creates financial benefits and conflicts for us as described below.
Lincoln Investment has designated the Dreyfus Government Cash Management Fund Service Shares for non-
ERISA 403(b)7 and 457(b) plans and participant accounts and as the secondary Sweep Product for balances in
excess of $2,490,000 in the Tiered Rate Sweep Product. Lincoln Investment has designated the Tiered Rate
Sweep Product for use in commission-based individual retirement accounts (IRAs) and most non-retirement
brokerage and advisory accounts, and has designated the Level Fee Sweep Product for use in advisory IRAs.
Lincoln Investment receives a portion of the fee paid to Pershing by the Program Banks in connection with the
Bank Deposit Sweep Products and receives distribution assistance payments from Pershing in connection with
the Dreyfus Government Cash Management Fund Service Shares Sweep Product. Accordingly, Lincoln
Investment has a conflict of interest in that we have a financial incentive to designate the Tiered Rate Sweep
Product, the Level Fee Sweep Product and/or the Dreyfus Government Cash Management Fund Service Shares
Sweep Product as the Sweep Product(s) for your account and, for discretionary advisory programs managed by
Lincoln Investment, Lincoln Investment can allocate a portion of assets to the Sweep Product, each of which
generates additional revenue to us. This compensation is a significant source of revenue for Lincoln Investment
and Pershing. Pershing, other financial services firms and third parties could offer the same or similar money
market mutual fund sweep products and/or bank deposit sweep products, at a lower overall cost and higher
return to the investor than is available through the Sweep Program, whether directly through the provider or
through a sweep program offered by a different financial services firm. This receipt of revenue sharing from
Pershing creates a conflict of interest to Lincoln Investment to use Pershing as a custodian over other custodians
that do not share these fees, do not share these payments or that would share lesser amounts or that would not
permit us to set our own fee, to offer the Sweep Products and to recommend that you utilize the Sweep Products.
Lincoln Investment receives a greater financial benefit when cash is swept into the above Bank Deposit Sweep
Products and Money Fund Sweep Product than it otherwise would if your cash balance is held elsewhere, and
any compensation the firm receives reduces the interest and/or dividend you receive, and your overall investment
return. This compensation is retained by the firm and is not shared with you. Lincoln Investment receives greater
compensation as assets and/or accounts utilizing the Sweep Products increase, as more fully described below.
The Sweep Product fees that we receive are in addition to any investment advisory fees that you pay to Lincoln
Investment and your Advisor. This means that Lincoln Investment earns two layers of fees on the same Sweep
Product balances in your account, which can result in you experiencing a negative overall investment return. We
also receive different fees based on the Sweep Product designated for your account. Therefore, we have an
incentive for you to use (and invest your assets in) the sweep products that increase our compensation. If you
desire to maintain a cash balance in your account for an extended period of time awaiting investment and/or seek
the highest yields currently available in the market for your cash balance, please contact your Advisor or Lincoln
Investment for options outside of the Sweep Products. In order to mitigate these conflicts, Lincoln Investment
does not share this revenue with your Advisor. Your Advisor has the ability to waive the advisory fee on all
Sweep Products, should you request it.
Lincoln Investment has designated the Tiered Rate Sweep Product for use in commission-based IRAs and most
non-retirement brokerage and advisory accounts, and has designated the Level Fee Sweep Product for use in
advisory IRAs. Bank Deposit Sweep Products are an important source of significant revenue for Lincoln
Investment, Pershing, and Pershing’s affiliated Program Banks that participate in the Sweep Program. For
additional information regarding Pershing’s and their affiliates’ conflicts of interest, please see the link to our
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Disclosures web page, included below. Lincoln Investment receives a portion of the fee paid to Pershing by the
Program Banks. Lincoln Investment sets the amount of the fee it receives from Pershing on your Bank Deposit
Sweep Product accounts and/or assets. This is a conflict of interest as it permits Lincoln Investment to assess a
higher fee to you in order to increase our revenue. Pershing offers other sweep products for which no
remuneration or less remuneration would be paid to Lincoln Investment, as introducing broker-dealer. The
portion of the fee received by us on the Bank Deposit Sweep Products is greater than the yield that you will
receive. Amounts paid to Lincoln Investment, Pershing and the Administrator reduce the interest rate paid on
your Bank Deposit Sweep Product balance. Therefore, the higher the compensation paid to us, the lower the
interest paid to you; the lower the compensation paid to us, the higher the interest paid to you. You should
understand that this can result in you experiencing a negative overall investment return with respect to your
balance in the Bank Deposit Sweep Product. Additionally, bank deposit sweep products typically yield lower
returns than money market mutual funds. However, because Lincoln Investment earns a higher fee when you
invest in Bank Deposit Sweep Products than if you invest in other money market products such as money market
mutual funds, within or outside of the Sweep Program, Lincoln Investment is incentivized to designate Bank
Deposit Sweep Products for your account(s). Lincoln Investment receives greater compensation related to Bank
Deposit Sweep Products as the amount of assets and/or accounts utilizing the Sweep Products increase and can
take up to 6.00% of the interest rate paid on the balances of your Deposit Accounts. For additional information
on Lincoln Investment’s current fees and compensation earned in relation to the Sweep Program, see the link to
our Disclosures web page, included below. Accordingly, these arrangements present a conflict of interest to
Lincoln Investment because they provide an incentive for us to offer the Bank Deposit Sweep Products as our
default sweep products, to maintain balances in the Bank Deposit Sweep Products over other investment options,
including money market mutual funds, and for us and your Advisor to recommend that you enroll in and utilize
the Bank Deposit Sweep Products. For Bank Deposit Sweep Products balances in excess of $2,490,000, Lincoln
Investment has designated a secondary Money Market Sweep Product. For the Tiered Rate Sweep Product, the
secondary Money Market Sweep Product is Dreyfus Government Cash Management Fund Service Shares
(Ticker symbol DGUXX). If your excess balance is swept into Dreyfus Government Cash Management Fund
Service Shares, Lincoln Investment will earn fees on that balance, as further discussed below. For the Level Fee
Sweep Product, the secondary Money Market Sweep Product is Dreyfus Government Cash Management Fund
Investor Shares (Ticker symbol DGVXX). For additional information regarding these secondary Sweep
Products, please see the link to our Disclosures web page, included below. Program Banks do not have a duty to
offer the highest rates available or rates that are comparable to money market mutual funds or those offered by
other depository institutions or deposits held at Program Banks outside of the Sweep Program. The receipt of
revenue sharing from Pershing and the ability for Lincoln Investment to set its fee for the Sweep Products
creates a conflict of interest for Lincoln Investment to use Pershing as a custodian and to offer the Bank Deposit
Sweep Products we make available to you over other custodians or sweep products that do not pay a portion of
their fees to us (share revenue), share lesser amounts, or that do not permit the introducing broker-dealer to set
the fee it will assess for the Sweep Products.
Lincoln Investment has designated the Dreyfus Government Cash Management Fund Service Shares for non-
ERISA 403(b)7 and 457(b) plans and participant accounts and as the secondary Sweep Product for balances in
excess of $2,490,000 in the Tiered Rate Sweep Product, and Dreyfus Government Cash Management Fund
Investor Shares Sweep Product for ERISA accounts and as the secondary Sweep Product for balances in excess
of $2,490,000 in the Level Fee Sweep Product.
A Money Fund Sweep Product earns dividends, interest and other income from its investment, and distributes
this income (less expenses) to shareholders as dividends. For the Dreyfus Government Cash Management Fund
Service Shares Sweep Product, Lincoln Investment utilizes a share class that provides remuneration to us
(distribution assistance) which reduces the dividend you receive, even though other share classes are available to
Lincoln Investment that would pay Lincoln Investment less and you more. Lincoln Investment receives
distribution assistance from Pershing in the form of annual compensation of up to 0.55% for assets in the
Dreyfus Government Cash Management Fund Service Shares Sweep Product. This is not the least expensive
share class of the Dreyfus Government Cash Management Fund available or the least expensive share class
available through Pershing. Lincoln Investment utilizes a higher expense share class over other less expensive
share classes that would otherwise be available and of lower cost to you. There are less expensive share classes
of the same money market mutual fund available that would not provide revenue sharing with Lincoln
Investment or would provide lesser amounts of revenue sharing to us. Share classes with higher expenses can
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lower your returns over time. This receipt of revenue sharing from Pershing creates a conflict of interest to
Lincoln Investment to use Pershing as a custodian and share classes offered by Pershing that provide
remuneration over other custodians and share classes that do not share these fees or payments, or that would
share lesser amounts, to offer the Sweep Products and to recommend that you utilize and maintain a greater
balance in the Sweep Products. Pershing offers other sweep products for which no remuneration or less
remuneration would be paid to Lincoln Investment, as introducing broker-dealer. The investment adviser to
Dreyfus Government Cash Management Fund Services Shares is BNYIA. BNYIA has engaged its affiliate,
Dreyfus, a division of Mellon Investments Corporation, to serve as the sub-investment adviser for Dreyfus
Government Cash Management Fund Services Shares. Lincoln Investment has an incentive to offer/recommend
Dreyfus Government Cash Management Fund Services Shares due to its agreement with Pershing which
incentivizes us to offer Pershing or its affiliates’ products so that we may share in a portion of the revenue.
The Dreyfus Government Cash Management Fund Investor Shares Sweep Product, for which no distribution
assistance is received by Lincoln Investment, is available only to ERISA accounts and as the secondary Sweep
Product for balances in excess of $2,490,000 in the Level Fee Sweep Product.
As previously indicated, certain Program Banks as well as Sweep Products affiliated with Pershing are made
available within the Sweep Program. Due to Lincoln Investment’s custodial and clearing arrangement with
Pershing, this creates a conflict of interest for Lincoln Investment because it provides an incentive for us to offer
a Sweep Product and to recommend utilizing the Sweep Product so that Pershing receives additional
compensation and shares it with us.
For additional information and clarity regarding all Sweep Products offered including the designated Sweep
Product and secondary Sweep Product for your account, eligibility criteria, as well as applicable fees, rates, bank
lists, and conflicts of interest, please carefully review our Sweep Program disclosures, available on our public
website under our Disclosures section or at https://www.lincolninvestment.com/Disclosures. Please refer to The
Lincoln Investment Companies Sweep Program General Terms and Conditions to access the applicable money
market mutual fund prospectus.
In aggregate, the third-party payments and revenue sharing from Pershing to Lincoln Investment attributable to
Lincoln Investment advisory accounts in 2025 described above represented approximately seven percent of Lincoln
Investment’s total advisory revenue in 2025. The receipt of these third-party payments and expense credits create a
conflict of interest to Lincoln Investment to use Pershing as a custodian over other custodians that do not share these
fees, do not provide expense credits or that would share lesser amounts. Lincoln Investment mitigates these conflicts
by disclosing them to you and not sharing these payments/credits with your Advisor.
Other Conflicts and Potential Conflicts Related to Our Relationship to Pershing and its Affiliates
Pursuant to a written agreement, Lincoln Investment is obligated to provide certain providers/custodians, such as
Pershing and its affiliates, including BNYMA, the opportunity to participate in Lincoln Investment’s conferences or
events, without the separate payment of sponsor or registration fees. The ability to participate in such events
provides Pershing, BNYMA and its affiliates the opportunity to promote their affiliated products and services to
Lincoln Investment, its affiliate Capital Analysts and our Advisors. Increased use of BNY affiliated products and
services by Advisors of the firm will benefit the firm by assisting us with meeting the asset levels required for us to
receive a reduction/waiver in certain Pershing/BNYMA expenses. Platforms/custodians, including
Pershing/BNYMA, can waive or negotiate their respective fees assessed to you, Lincoln Investment and/or its
affiliates, and/or your Advisor, in each platform/custodian's sole discretion. Lincoln Investment and/or its affiliates
are not required to pass the waiver/reduction in cost along to you. We recognize these as conflicts for Lincoln
Investment and its affiliate, Capital Analysts, and mitigate these conflicts by disclosing them to you.
Sales & Marketing Support Revenue
Lincoln Investment receives Sales and Marketing Support as described below and includes Flat Fee Sponsors, Other
Sales Support and Asset and Sales Based Sponsors (collectively, “Sales and Marketing Support”). In order to
minimize the conflicts associated with the receipt of these fees, Lincoln Investment does not receive Flat Fee
Sponsor and Other Sales Support payments that are based on the amount of advisory account assets or advisory
account transactions with a particular sponsor, or that are based on ERISA advisory account assets. However, Flat
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Fee and Other Sales Support Sponsors can compensate Lincoln Investment from assets of the mutual fund, the
fund’s investment adviser, distributor or other fund affiliate’s assets. While payments out of the fund's investment
adviser, distributor or other fund affiliate's revenues or profits are not directly paid from the fund's assets, fund
affiliate revenues or profits can, in part, be derived from fees earned for services provided to and paid for by the
fund. Payments out of fund assets can lower investor returns and performance over time. Lincoln Investment can
also receive Shareholder Services Fees from the same fund families and investment advisers that provide Sales and
Marketing Support. These sources of payments are a conflict of interest to Lincoln Investment to recommend and
promote those funds, fund families, investment advisers, distributors or other fund affiliates over others that do not
provide Sales and Marketing Support or that provide lower amounts of Sales and Marketing Support.
Flat Fee Sponsors. Lincoln Investment has partnered with a select group of third-party money managers and
product sponsors who pay to assist Lincoln Investment in the training and education of and outreach to Lincoln
Investment’s Advisors, at Lincoln Investment sponsored events, on such topics as advisory products and
services, practice management, tools and technology, consumer education, and policies, rules and regulations.
Additional opportunities can include but are not limited to attendance at and support of recognition club events,
exhibit booths, advisor presentations, seminars, mailings and publications. These sponsors provide financial
support to Lincoln Investment in the form of a flat-dollar amount that may be amended annually and is not based
on the sales of their proprietary products or services. Sponsors can compensate us from fund assets, the fund’s
investment adviser, distributor or other affiliate’s assets. Payments made out of fund assets can lower investor
returns and performance over time. Advisors do not share in any portion of these payments so as to mitigate any
conflict for an Advisor to recommend one product or money manager over another. This financial support allows
Lincoln Investment to defray or offset costs associated with Lincoln Investment sponsored events and other
educational and outreach tools and services. The financial support by these Sponsors to Lincoln Investment
presents a conflict of interest.
All Flat Fee Sponsors do not pay Lincoln Investment the same amount, and depending on the amount of the
payment from the Flat Fee Sponsor, the access to Lincoln Investment sponsored events can differ. For example,
Lincoln Investment holds a number of sales conferences both nationally and regionally throughout the year to
educate advisors. The higher the annual flat fee payment, the more events the Flat Fee Sponsor will be invited to
attend. Flat Fee Sponsors have more opportunities than other product sponsors and money managers that are not
Flat Fee Sponsors to market to and educate Advisors, which could pose a conflict to Advisors to offer these
sponsors’ products or services over others. Advisors do not share in any portion of these payments so as to
mitigate any such conflict.
In 2025, the financial support from Flat Fee Sponsors paid to Lincoln Investment, as allocated across all
investment advisory assets with Lincoln Investment Planning, LLC and its affiliate, Capital Analysts, LLC did
not exceed one percent of total revenue for either of the affiliated registered investment advisers and in aggregate
was less than one percent of the combined revenue for both affiliated registered investment advisers. We do not
believe that these revenues are material. In 2025, Flat Fee Sponsors who compensated Lincoln Investment with a
flat fee payment, and offer a fund or advisory program that could be used in your advisory account, in order from
highest to lowest payment were Russell Investments, Clark Capital Management, AAMA, American Funds,
PIMCO Funds, Meeder Funds, Security Benefit Life, Nationwide, Transamerica Life, Federated Investors, BNY
Mellon, and Doubleline.
Some of the Flat Fee Sponsor revenue is used by Lincoln Investment to support the ongoing operational
expenses of Lincoln Investment, and its affiliates, and not used solely for sales and marketing support.
Other Sales Support. From time to time, product sponsors and third-party money managers assist Advisors in
their sales and marketing efforts by subsidizing certain Advisor costs, such as client meetings or workshops,
mailings, administrative expenses and technology support. The amount received from any one product sponsor
or third-party money manager in 2025 did not exceed $35,000. The sales support presents a conflict of interest in
that it could incentivize an Advisor to offer one product or money manager over another that does not provide
these subsidies or provides lesser amounts. To mitigate the conflict of interest presented by these payments and
subsidies, the amount is approved by Lincoln Investment and is monitored to ensure that it is not too frequent or
excessive. Also, Advisors are invited from time-to-time by product sponsors to due diligence and educational
meetings or seminars hosted by the product sponsor or money manager. This presents a conflict of interest that
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could incentivize an Advisor to offer one product or money manager over another that does not offer these
meetings or seminars. Lincoln Investment must grant permission to our Advisors to attend any meeting or
seminar hosted by a product or advisory service sponsor. Lincoln Investment approves events that are limited to
education or due diligence only and allows the product sponsor to provide meals, hotel accommodations and
reimbursement to the Advisor, through Lincoln Investment, for travel expenses only. The education of our
Advisors in the offerings that are available to them is a key component of providing prudent investment advice
to you.
Ancillary Sales & Marketing Support Revenue paid to Lincoln Investment that is not tied to your Advisory
assets, or the platform where your Advisory assets are held, but is tied to the Non-Advisory assets or
transactions in which you may invest
Asset and Sales Based Sponsors. In connection with non-investment advisory (non-fee-based) assets of our
investors, and in addition to the compensation described above, Lincoln Investment receives Sales and
Marketing support from product sponsors, mutual fund companies, insurance companies and other third-party
providers to assist in the marketing and sales efforts of employees and Advisors (“Asset and Sales Based
Sponsors”). Asset and Sales Based Sponsors have the opportunity to educate and train employees and Advisors
with respect to investment products and services, practice management, tools and technology, consumer
education, and policies, rules and regulations. Additional opportunities can include but are not limited to
attendance at and support of recognition club events, exhibit booths, advisor presentations, seminars, mailings
and publications. The support provided by these sponsors is based on brokerage-only (non-investment advisory)
assets and brokerage transactions and not based on your advisory account assets or ERISA advisory assets. We
receive compensation from these sponsors in various forms, including as a flat fee, a percentage of the amount of
brokerage assets held by investors, a percentage of sales, or any combination of these methods. The amounts of
these payments can vary by the type of product and by provider and can include, but are not limited to,
distribution fees and shareholder service fees. All Asset and Sales Based Sponsors do not pay Lincoln
Investment the same amount, and depending on the amount of the payment, the access to Lincoln Investment
sponsored events and other opportunities can differ. The higher the payment, the greater the access for the Asset
and Sales Based Sponsor to attend events, participate in marketing and sales opportunities and interact with
Advisors. This presents a conflict of interest to Advisors to offer these sponsors’ products or services over
others. Advisors do not share in any portion of these payments so as to mitigate any such conflict. Additionally,
some Asset and Sales Based Sponsors make a monthly or quarterly payment or additional monthly or quarterly
payment based on the assets you hold in a fund or variable insurance product over a period of time. As you may
have both a brokerage account and an advisory account with us, we want you to understand that Lincoln
Investment will receive Sales and Marketing Support based on assets or sales in connection with your brokerage
account assets and transactions. The Asset and Sales Based Sponsors payments present a conflict of interest to
Lincoln Investment to recommend Asset and Sales Based Sponsors that provide sales and marketing support
over others that do not or that provide lesser amounts. Some of the Asset and Sales Based Sponsor revenue is
used by Lincoln Investment to support the ongoing operational expenses of Lincoln Investment, and its affiliates,
and not used solely for sales and marketing support.
The following is a list of Asset and Sales Based Sponsors in order of high to low total compensation paid to
Lincoln Investment as broker-dealer based on non-fee based account assets or sales in 2025: Security Benefit
Life, Franklin Templeton Group, Jackson National Life Ins Co, Allianz, Lincoln National Life, Athene,
Nationwide, AXA Equitable Life Insurance Company, Prudential, Brighthouse Financial, Pacific Life,
Transamerica Life, Mewbourne Development Corporation, Simplicity, the Standard, Pershing, Blue Rock
Capital, Voya Mutual Funds, and Meeder Funds. The Asset and Sales based Compensation in 2025 was less than
$3 million dollars from these product sponsors and represented less than one percent of the total revenues of
Lincoln Investment. We are disclosing this information to you as certain providers and products offered by the
providers shown above could be available within our investment advisory offerings.
Outside of the Sweep Program, Pershing, as clearing firm for accounts introduced by Lincoln Investment, shares
with Lincoln Investment a nominal amount of asset-based revenue it receives from certain mutual fund
companies in non-advisory accounts. As this revenue received from Pershing is non-advisory related and not
material, Lincoln Investment is disclosing the conflict that we receive this revenue rather than list each mutual
fund product that generated the compensation to the firm.
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Other Conflicts and Potential Conflicts
Loans, Advances and Other Benefits. Lincoln Investment can extend loans, provide bonuses and other
benefits, provide commission/fee advances, and pay for practice management services for an Advisor to assist
the Advisor in transitioning to the firm, and/or maintaining or expanding his or her business. Lincoln Investment
does not verify that any payments made are used for these purposes. Sometimes the availability and amount of
loans and advances are conditioned upon, are forgiven (waived) or reduced, in whole or in part, interest rates
reduced, and/or bonuses provided if an Advisor remains affiliated with the firm or achieves certain sales or
assets under management thresholds, revenue targets, production levels, asset additions, new client goals, client
retention goals, recruiting goals and certain practice management goals or conditions, individually or with other
Advisors. These practices present a conflict of interest in that the Advisor has a financial incentive to affiliate
with and remain affiliated with the firm during the repayment period in order to receive these benefits over other
firms that do not offer these incentives or offer a similar level of incentives. These practices also present a
conflict in that the Advisor has a financial incentive to generate more business or to recruit other financial
professionals to generate more business, and achieve certain sales, revenue, asset additions or asset management
thresholds in order to receive a loan or advance, increase the amount of the loan or advance, and/or satisfy or
reduce the amount of the loans or advances. The extent of the conflict can increase as your Advisor approaches
certain milestones. In situations where a sales, production, recruiting, revenue, asset additions, assets under
management threshold or other financial contingency exists, this conflict of interest will be disclosed in your
Advisor’s Form ADV 2B Supplement (“BIO Brochure”), which is required to be delivered by the Advisor to
every client. Lincoln Investment mitigates these conflicts by disclosing them to you and supervising the
investment advisory activities and brokerage practices of its Advisors.
Additionally, Lincoln Investment can extend a loan or advance to an Advisor for which repayment is required
which can create a conflict for the Advisor to generate more business in order to repay the loans or advances to
the firm during the repayment period. Additionally, some Advisors receive benefits as they transition to the firm
and/or for maintaining their business, which can include but is not limited to, technology services, administrative
support, licensing, insurance and administrative fees, the opportunity to participate in a unit appreciation rights
plan of an affiliate or parent of Lincoln Investment, and reimbursement of fees associated with transitioning
accounts. These practices present a conflict of interest in that the Advisor has a financial incentive to affiliate
with and remain affiliated with the firm over other firms that do not offer these incentives or offer a similar level
of incentives. Lincoln Investment mitigates these conflicts by disclosing them to you and supervising the
investment advisory activities and brokerage practices of its Advisors.
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Item 3: Table of Contents
Item 1: Cover Page .......................................................................................................................... 1
Item 2: Material Changes ................................................................................................................ 2
Item 3: Table of Contents ............................................................................................................... 12
Item 4: Services, Fees and Compensation ..................................................................................... 13
Item 5: Account Requirements and Types of Clients ..................................................................... 43
Item 6: Portfolio Manager Selection and Evaluation .................................................................... 43
Item 7: Client Information Provided to Portfolio Managers ......................................................... 50
Item 8: Client Contact with Portfolio Managers ........................................................................... 50
Item 9: Additional Information ...................................................................................................... 50
Brochure Supplement(s) included:
• Form ADV Part 2A
•
Investment Management & Research Team Brochure Supplement (Form ADV Part 2B)
Lincoln Investment’s Form ADV Part 2A, Items 1 - Item 17, is included and to be delivered together with this
Lincoln Investment Form ADV Part 2A – Appendix I.
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Item 4: Services, Fees, and Compensation
This section will describe the wrap fee programs sponsored by Lincoln Investment Planning, LLC (“Lincoln” or
“Lincoln Investment”), how we tailor these programs to your individual needs, and which of our wrap fee
programs allows you to impose investment restrictions. This section also provides a description of our wrap fees,
how and when these wrap fees are collected, and if refunds are available. Other types of fees and expenses that you
may incur are described below in the section titled, "Other Costs That You May Incur." Other types of
compensation that Lincoln Investment and your Advisor could receive, which could create a conflict of interest, are
described below in the section titled, "Other Compensation to Lincoln Investment and Our Conflicts of Interest."
Our Fiduciary Role… Lincoln Investment and your Advisor assume a fiduciary duty to provide to you investment
recommendations that are in your best interest. This fiduciary duty extends to all advisory accounts that you
maintain with us, but such fiduciary duty does not extend to brokerage or other non-advisory accounts or
investments. The level of monitoring in your advisory account will depend on the type of account and the advisory
program you select. Where Lincoln Investment has full discretionary trading authority over your advisory account,
Lincoln Investment will provide ongoing monitoring and will make changes in your account as deemed
necessary. For all other advisory accounts, you and your Advisor will review your advisory account’s objectives,
investments and performance relative to your objectives and financial situation at least annually to allow your
Advisor the opportunity to recommend changing or maintaining the objectives or investments in your account. See
your investment advisory agreement for the level of discretion and monitoring granted to Lincoln Investment or
your Advisor, which can vary based on the advisory program you select.
Investment Advice Provided to Certain Retirement and Tax-Advantaged Accounts
When we and/or your Advisor provide investment advice to you regarding your Covered Retirement Plans, Lincoln
Investment and your Advisor are fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act of 1974, as amended (“ERISA”) and/or the Internal Revenue Code (“IRC”), 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 and your Advisor to act in your best interest and not put our interest
ahead of yours. Under this special rule’s provisions, we and your Advisor must: meet a professional standard of care
when making investment recommendations (give prudent advice); not place 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 reasonably 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. Covered Retirement Plans include the following account types: Individual Retirement Account (“IRA”);
Individual Retirement Annuity; Roth IRA, Beneficiary IRA, Beneficiary Roth IRA; SEP-IRA, SARSEP, SIMPLE
IRA; One-Participant 401(k); Health Savings Account; Archer Medical Savings Account; Coverdell Education
Savings Account; and Accounts held by ERISA Title I Plan participants/beneficiaries with authority to direct the
distribution of assets from their account. When we provide investment advice to your Covered Retirement Plan as
described in this paragraph, we will disclose to you the types of services to be provided and material facts relating to
conflicts of interest that are associated with the recommendations made to you. These disclosures are provided to
you in various documents, including The Lincoln Investment Companies Investor Agreement and Disclosure
Handbook, Lincoln Investment’s Form CRS and its affiliated investment adviser, Capital Analysts’ Form CRS, your
Advisor’s BIO Brochure (Form ADV Part 2B), account applications, prospectuses, and specific platform or program
disclosure documents, and the Investment Advisory Disclosure Brochure of Lincoln Investment (Form ADV Part
2A and Wrap Fee Program Brochure).
General Information Regarding Wrap Fee Programs
A Wrap Fee Program is an investment advisory program in which you pay one bundled fee to compensate Lincoln
Investment and your Advisor for their services and to pay the transaction and clearing costs associated with
transactions in your advisory account. Lincoln Investment offers Wrap Fee Programs in addition to the advisory
services described in the Form ADV Part 2A Brochure attached.
Lincoln Investment's Wrap Fee Programs are offered on brokerage platforms where securities such as mutual funds,
stocks, bonds, exchange-traded funds (“ETFs”), exchange-traded notes (“ETNs”) and options are offered. Certain
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platforms can apply transaction-related costs for trades in these securities. The Wrap Fee is not based directly upon
the actual transaction or execution costs of the transactions in your account.
Depending on the underlying investments and amount of transactions you expect to be executed in your account, a
Wrap Fee account may cost you more than if you chose another Lincoln Investment advisory program that does not
offer a Wrap Fee, or if you chose to pay separately for all of your transaction costs (e.g., pay the advisory fee plus all
ticket charges). In general, you should only choose a Wrap Fee Program if you or your Advisor expect to trade
regularly in the account.
Similarly, if you are interested in a mutual fund-only portfolio or an ETF-only portfolio, then a Wrap Fee Program
may not be the lowest cost option for you. Pershing and Schwab offer a number of funds and ETFs on both their No
Transaction Fee menu and their Transaction Fee menu. If you wish to consider a Wrap Fee program, Lincoln offers
Wrap Fee programs on Pershing and for a limited number of Advisors, on Schwab. Lincoln Investment’s Wrap Fee
accounts at Schwab can utilize mutual funds and ETFs with transaction fees and with no transaction fees. For details
on mutual fund share class in accounts held at Pershing, see Lincoln Investment’s Share Class Selection Policy for
Advisory Accounts under Other Compensation to Lincoln Investment and Our Conflicts of Interest. In lieu of
transaction fees, Lincoln Investment pays an asset-based fee to Pershing to cover the trade execution and clearing
costs for equity securities, ETFs, fixed income, and options on the Pershing platform. For mutual funds, Lincoln
Investment is assessed a surcharge for transactions in certain mutual funds, but otherwise is not assessed a
transaction fee for mutual fund trades on the Pershing platform. Due to this arrangement with Pershing, Lincoln
Investment has financial incentive to recommend to you no-surcharge mutual fund only portfolios in your Wrap
Accounts on Pershing in order to minimize its expenses. Where Lincoln Investment is assessed transaction costs,
Lincoln Investment has a financial incentive to minimize the costs that will be assumed by the firm on your behalf
by not placing transaction orders in those accounts as doing so would increase Lincoln Investment’s transaction
costs. Thus, an incentive exists to place trades less frequently in a wrap fee arrangement. Your Advisor will review
your investment objectives with you to determine the best offering for you.
Your Advisor will work with you to recommend a Wrap Fee Program(s) based on your confidential investor profile,
in which you provide to Lincoln Investment and your Advisor personal and financial information including, but not
limited to, your investment goals, income requirements, time horizon, and tolerance for risk in order to tailor his or
her recommendations to your needs and objectives.
You may not have the opportunity to place reasonable restrictions on the types of investments that are purchased in
certain Wrap Fee Programs. Please contact your Advisor to discuss any allowable investment restrictions in the
Wrap Fee Program(s) you have selected. Further details regarding your specific Wrap Fee Program can be found in
your investment advisory agreement.
The services and costs covered by the Wrap Fee are:
Investment advice provided by Lincoln Investment and your Advisor;
Investment management provided by Lincoln Investment or your Advisor;
• Financial and life planning consultation by your Advisor, as needed or requested by you;
•
•
• Clearing and trading costs associated with transactions and/or positions in the account, such as ticket
charges, surcharge fees for certain no load and load waived funds and confirmation fees (for accounts
custodied at Pershing LLC only);
• Short-term trading costs imposed by mutual funds and/or Pershing for trades occurring within Lincoln
Investment Managed Programs;
• Charges imposed if certain investment minimums are not met; and
• Monitoring of your advisory account(s).
However, your Wrap Fee will not cover standard account administrative fees such as statement fees, electronic fund
and wire transfer charges, account service fees, annual retirement account fees, termination fees, and fees for trades
executed away from the custodian.
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You could purchase services similar to those offered in Lincoln Investment's Wrap Fee Programs separately from
our affiliated investment adviser, Capital Analysts, LLC, or unaffiliated financial services providers. Wrap Fee
Programs may cost you more or less than purchasing the services from another investment adviser. Some cost
factors to consider, other than the Wrap Fee itself, when considering an investment advisory offering include:
• Account custody fees
• Account maintenance and special handling fees, such as wire funds fees
• Volume of trading activity anticipated in your account
• Commissions or ticket charges to be charged in lieu of a Wrap Fee
• Account termination fees
• Account statement and confirmations fees
You should review the costs for each of the management services separately, as well as mutual fund and ETF fees
and expenses where applicable, when analyzing the cost of Lincoln Investment's Wrap Fee Programs. Please contact
your Advisor for a schedule of fees and costs associated with our Wrap Fee Program(s).
The Financial Advisor Fee. Your Advisor receives a portion of the Wrap Fee you pay, which compensates your
Advisor for his or her services (“Financial Advisor Fee”). This fee is an annual fee that continues as long as you
maintain your account with us. Unless otherwise stated, your Advisor’s fee is negotiable at the Advisor’s sole
discretion and to a maximum fee that is established by Lincoln Investment. The maximum annual Financial Advisor
Fee that your Advisor can charge for his/her services is 1.25% of the assets being advised or managed. Advisor
managed services and fees typically differ by Advisor, and the Financial Advisor Fee can vary based on advisory
services offered. Your Advisor will share in all or a portion of the Financial Advisor Fee based on their payout
schedule with Lincoln Investment. The amount of this compensation may be more than what your Advisor would
receive from other advisory services offered by Lincoln Investment, or more than if you paid separately for
investment advice, brokerage, and other services. This fee provides access to your Advisor for financial and life
planning consultation, as requested by you, as well as investment advice services which include assisting you in the
determination of the appropriate investment advisory investments and advisory programs for you, conversing with
you on an as-needed or as requested basis, but, at minimum, annually, to ensure that the investments and programs
continue to meet your stated objectives and needs. It is important therefore that you make the time to speak with
your Advisor at least annually or whenever there is a material life event that could affect or change your investment
objectives or financial needs.
Description of Wrap Fee Programs and Fees
Lincoln Investment makes available an investment advisory platform custodied at Pershing LLC (“Pershing”)
referred to as “Lincoln Signature Solutions.” The Lincoln Signature Solutions platform offers two (2) main product
lines: Lincoln Workplace Retirement Solutions for non-ERISA 403(b) and 457 employer retirement plans and
Lincoln Wealth Solutions for most other investors whose assets are custodied at Pershing. Below is a description of
the Wrap Fee Programs offered on the Lincoln Signature Solutions platform. For additional Wrap Fee Programs
offered outside of the Lincoln Signature Solutions platform on Pershing or other third-party custodians, see the
“Other Wrap Fee Programs” section below.
Lincoln Signature Solutions Wrap Fee Programs
Lincoln Investment sponsors and currently offers the following Wrap Fee Programs on the Lincoln Signature
Solutions platform.
• Premier Asset Management;
• Select Manager;
• Manager Access;
• Unified Managed Account (UMA); and
• Personal Portfolio Management (PPM)
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Depending upon the Program(s) you select, Lincoln Investment or a third-party money manager, including, but not
limited to, BNY Mellon Advisors, Inc., an investment adviser registered with the Securities and Exchange
Commission (“BNYMA”) can act as model provider for your Account (“Model Provider(s)”) by providing model
portfolios to the Overlay Manager. Model Providers design each model portfolio for a certain level of risk tolerance
and investment objective and select mutual funds, exchange-traded funds (“ETFs”), exchange-traded notes
(“ETNs”) and/or equity and fixed income securities that it believes are appropriate for each model portfolio. Lincoln
Investment or the third-party money manager, when acting as Model Provider, will transmit investment instructions
to the Overlay Manager. With regard to third-party Model Providers, Lincoln Investment relies on the expertise and
management disciplines of the Model Provider, when they are engaged, to provide model portfolios that align to
each model’s stated discipline and risk level. Lincoln Investment, however, retains the authority to change Model
Providers at any time. If a Model Provider or model portfolio ceases to be available or is removed from Lincoln
Investment's offerings, Lincoln Investment will notify you in writing and indicate, if appropriate, an alternative
offering.
BNY Mellon Advisors, Inc. (“BNYMA” or “Overlay Manager”), can also act as Overlay Manager with respect to
model portfolios supplied by Model Providers by providing portfolio trading, implementation and coordination
services for the designated assets in your account. The Overlay Manager acts with discretionary authority (“Overlay
Discretion”) by allocating assets across the selected model portfolio(s), ETFs, mutual funds and other securities in
accordance with Model Provider instructions for the selected program, implementing model changes received from
Model Providers, rebalancing your account in accordance with target allocations and program trading parameters,
and implementing specific restrictions placed on the account, all without prior consent from or consultation with
you. Model Provider instructions received by Overlay Manager may be implemented in whole or in part, or
disregarded at the Overlay Manager’s sole discretion. Overlay Manager services are not available for Separate
Account portfolios or Client Custom Portfolios (see Lincoln Investment’s Form ADV Part 2A for more information
on the Client Custom Portfolios advisor-managed non-wrap fee program offered as part of Lincoln Signature
Solutions). Lincoln Investment can change the Overlay Manager at any time in its sole discretion to another
unaffiliated investment adviser, an affiliated investment adviser or Lincoln Investment itself can assume, replace or
add the responsibilities of the Overlay Manager, subject to providing notice to you.
Should you select a separately managed account, Lincoln Investment or a third-party money manager, including, but
not limited to, BNYMA, can act as separate account manager for your Account (“Separate Account Manager”) by
trading your account directly in accordance with the strategy you select. Separate Account Managers manage your
investment portfolio following a defined strategy (“Separate Account”). The holdings in the Separate Account
portfolio can be comprised of equity securities, fixed income securities, mutual funds, ETFs, ETNs, options and/or
cash. All investment decisions and trades for a Separate Account are the responsibility of the respective Separate
Account Manager. Separate Accounts are not available on Lincoln Workplace Retirement Solutions. With regard to
third-party Separate Account Managers, Lincoln Investment relies on the expertise and management disciplines of
the Separate Account Managers, when they are engaged, to manage accounts directly in accordance with the
selected strategy. Lincoln Investment, however, retains the authority to change Separate Account Managers at any
time. If a Separate Account Manager or strategy ceases to be available or is removed from Lincoln Investment's
offerings, Lincoln Investment will notify you in writing and indicate, if appropriate, an alternative offering.
For all of the above programs, your Advisor will review your account to ensure the selected manager and model
portfolio or Separate Account remain consistent with your goals and objectives based on the information you
provide to your Advisor. Your Advisor will be available to you to provide investment advice regarding the selected
program, but you will make the ultimate decision regarding the selection of a Model Provider or Separate Account
Manager and model portfolio or separately managed account portfolio. You are responsible to notify your Advisor
of any changes in your financial situation, risk tolerance or investment objectives, and to let us know of any
investment restrictions that you wish to impose so that your Advisor can suggest the appropriate advisory service for
you. Contact your Advisor if you wish to impose investment restrictions.
In addition to the Financial Advisor Fee, you will also pay an annual asset-based Platform Fee depending on your
account type, as outlined in the tables below and as part of your investment advisory agreement.
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Platform Fee
Wealth Solutions (Applicable to non-
403(b)/457(b) accounts)
Assets
First $500,000
$500,000 - 1,000,000
$1,000,000 - 2,000,000
$2,000,000 – 5,000,000
$5,000,000 – 10,000,000
$10,000,000 – 20,000,000
$20,000,000 – 35,000,000
Over $35,000,000
Platform Fee
0.15%
0.12%
0.10%
0.08%
0.06%
0.04%
0.03%
0.02%
Workplace Retirement Solutions (Applicable to
403(b)/457(b) accounts)
Assets
First $500,000
$500,000 - 1,000,000
$1,000,000 - 2,000,000
$2,000,000 – 5,000,000
$5,000,000 – 10,000,000
$10,000,000 – 20,000,000
$20,000,000 – 35,000,000
Over $35,000,000
Platform Fee
0.24%
0.21%
0.19%
0.17%
0.15%
0.15%
0.15%
0.15%
In addition, depending on the program you select, you will also pay a Manager Fee, UMA Fee and/or Sponsor Fee.
These fees are outlined below under the respective platform/program(s) to which they apply, and in your investment
advisory agreement.
Lincoln Wealth Solutions Wrap Fee Programs - Maximum Annual Advisory Fee by Program
Program
Max.
UMA Fee
Max.
Total Fee
Max.
Platform
Fee
Max.
Manager
Fee
Max.
Sponsor
Fee
Max.
PPM
Fee
Max.
Financial
Advisor
Fee
1.25%
0.15%
0.30%
N/A
N/A
N/A
1.70%
1.25%
1.25%
0.15%
0.15%
0.65%
1.00%
N/A
0.10%4
N/A
N/A
N/A
N/A
2.05%
2.50%
1.25%
0.15%
1.00%
0.05%
N/A
2.55%
Varies by
Sleeve5
1.25%
0.15%
N/A
N/A
N/A
0.15%
1.55%
Premier Asset
Management
Select Manager
Manager Access¹
UMA-Unified
Managed
Account²
PPM-Personal
Portfolio
Management³
¹ Minimum investment amounts range from $50,000 to $500,000.
² Minimum investment for the UMA Program is $75,000; however, investment minimums for Sleeve Managers selected in the UMA
Program can exceed $75,000.
³ Minimum investment for the PPM Program is $10,000.
4 The Sponsor Fee is assessed on a tiered schedule as follows: 0.10% on assets $0 to $500,000; 0.07% on assets $500,000.01-$1,000,000;
0.05% on assets $1,000,000.01 and above.
5 Sponsor Fee applies to Manager Access sleeve assets, if any, within the UMA Program.
Lincoln Workplace Retirement Solutions Wrap Fee Programs - Maximum Annual Advisory Fee by Program
Program
Max. UMA
Fee
Max. PPM
Fee
Max. Total
Fee
Max.
Financial
Advisor Fee
Max.
Platform
Fee
Max.
Manager
Fee
1.25%
0.24%
0.30%
N/A
N/A
1.79%
1.25%
0.24%
0.30%
N/A
N/A
1.79%
1.25%
0.24%
0.30%
0.05%
N/A
1.84%
1.25%
0.24%
N/A
N/A
0.15%
1.64%
Premier Asset
Management
Select Manager
UMA-Unified
Managed
Account¹
PPM-Personal
Portfolio
Management
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March 2026
¹ Minimum investment for the UMA Program is $75,000; however, investment minimums for Sleeve Managers selected in the UMA
Program can exceed $75,000.
Premier Asset Management Program
The Premier Asset Management Program provides Lincoln Wealth Solutions investors with access to (i) model
portfolios supplied by Lincoln Investment’s IM&R Team comprised of mutual funds, ETFs, equity and fixed
income securities, and (ii) separately managed account portfolios managed by the IM&R Team, comprised of equity
securities, fixed income securities, mutual funds, ETFs, ETNs, options and/or cash. The Premier Asset Management
Program provides Lincoln Workplace Retirement Solutions investors with access to model portfolios supplied by
the IM&R Team comprised of mutual funds and exchange-traded funds that are regulated investment companies
(“RICs”) under Section 851(a) of the IRC and are eligible 403(b) investments ("Eligible ETFs"). Lincoln Investment
will act with full discretion to manage the assets allocated to the Premier Asset Management Program, including
purchases, sales, allocations, reallocations, reinvestments or rebalances of the program assets, all without prior
consent from or consultation with you. Overlay Manager will act with Overlay Discretion with respect to model
portfolios within the Premier Asset Management Program. The IM&R Team provides ongoing monitoring for model
portfolios and separately managed accounts within the Premier Asset Management Program. Overlay Manager
provides ongoing monitoring of model portfolio implementation and coordination services for assets in the Premier
Asset Management Program.
Please refer to Item 8: Methods of Analysis, Investment Strategies and Risk of Loss for a description of the primary
investment strategies utilized in Lincoln Investment managed model portfolios in the Premier Asset Management
Program.
Manager Fees for Premier Asset Management Programs
Manager Fee - Standard Schedule¹
Assets
First $500,000
$500,000.01 - 1,000,000
$1,000,000.01 - 2,000,000
$2,000,000.01 – 5,000,000
$5,000,000.01 – 10,000,000
$10,000,000.01 – 20,000,000
$20,000,000.01 – 35,000,000
Over $35,000,000
Manager Fee
0.30%
0.28%
0.25%
0.23%
0.20%
0.19%
0.19%
0.19%
Manager Fee – AIM/CAAMS ETF Model
Portfolios and Managed Fixed Income²
Assets
First $500,000
$500,000.01 - 1,000,000
$1,000,000.01 - 2,000,000
$2,000,000.01 – 5,000,000
$5,000,000.01 – 10,000,000
$10,000,000.01 – 20,000,000
$20,000,000.01 – 35,000,000
Over $35,000,000
Manager Fee
0.15%
0.13%
0.10%
0.10%
0.10%
0.10%
0.10%
0.10%
Manager Fee - CAAMS Stock SMA
Assets
First $500,000
$500,000.01 - 1,000,000
$1,000,000.01 - 2,000,000
$2,000,000.01 – 5,000,000
$5,000,000.01 – 10,000,000
$10,000,000.01 – 20,000,000
$20,000,000.01 – 35,000,000
Over $35,000,000
Manager Fee
0.30%
0.25%
0.20%
0.19%
0.19%
0.19%
0.19%
0.19%
¹ AIM Active/AIM Active US Focus, AIM ESG, AIM ETF/AIM ETF US Focus, AIM Hybrid, AIM Index, AIM Risk-Managed Equity,
CAAMS Active ETF, CAAMS Active ETF International Focus, CAAMS Complete/CAAMS Complete Tax Aware, CAAMS ETF ESG,
CAAMS ETF Managed Volatility, Dividend Portfolios, Lincoln Strategic, Progressive Asset Management, Progressive ESG, Unified
Wealth Portfolio Dynamic/Unified Wealth Portfolio Dynamic US Focus, Unified Wealth Portfolio Strategic/Unified Wealth Portfolio
Strategic US Focus.
² AIM Index ETF, CAAMS ETF/CAAMS ETF Tax Aware, CAAMS ETF Fixed Income and Managed Fixed Income only.
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March 2026
Premier Asset Management Program Offerings
Discipline
Advisory Offering
Investment Types
Custodian of Assets
Strategic
Dividend Portfolios
Minimum
Investment
$25,000
Pershing LLC
Strategic
Lincoln Strategic
$10,000
Pershing LLC
Strategic
$25,000
Mutual funds and
ETFs
Mutual funds and
ETFs
Mutual funds
Pershing LLC
Strategic
Pershing LLC
Strategic
Pershing LLC
Strategic
$100/
$10,0003
$100/
$10,0003
$25,000
Pershing LLC
Lincoln Strategic
Catholic Values
Lincoln Strategic
Vanguard
Progressive Asset
Management¹
Progressive Asset
Management ESG²,4
Strategic
Strategic
$50,000
$25,000
Mutual funds and
ETFs
Mutual funds and
ETFs
Mutual funds and
ETFs, (primarily
ESG funds, but non-
ESG funds can also
be utilized)
ETFs
ETFs
Pershing LLC
Pershing LLC
Strategic
$50,000
Pershing LLC
Mutual funds and
ETFs
Strategic
$50,000
ETFs
Pershing LLC
Strategic
Strategic
$50,000
$25,000
ETFs
ETFs
Pershing LLC
Pershing LLC
Strategic
$50,000
ETFs
Pershing LLC
Strategic
$100,000
Pershing LLC
Strategic
$100,000
Pershing LLC
Mutual funds, ETFs,
stocks and bonds
Mutual funds, ETFs,
stocks and bonds
Dynamic
Pershing LLC
CAAMS Active ETF
CAAMS Active ETF
International Focus
CAAMS Complete;
CAAMS Complete Tax
Aware
CAAMS ETF; CAAMS
ETF Tax Aware
CAAMS ETF ESG4
CAAMS ETF Fixed
Income
CAAMS ETF Managed
Volatility
Unified Wealth
Portfolio Strategic
Unified Wealth
Portfolio Strategic U.S.
Focus
Adaptive Intelligence
Models (AIM) Active
$100/
$10,0003
Dynamic
AIM Active U.S. Focus
Pershing LLC
$100/
$10,0003
Dynamic
AIM ESG4
Pershing LLC
$100/
$10,0003
Mutual funds and
ETFs (primarily
actively managed
funds, but passively
managed funds can
also be utilized)
Mutual funds and
ETFs (primarily
actively managed
funds, but passively
managed funds can
also be utilized)
Mutual funds and
ETFs, (primarily
ESG funds, but non-
ESG funds can also
be utilized)
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March 2026
Premier Asset Management Program Offerings
Discipline
Advisory Offering
Investment Types
Custodian of Assets
Dynamic
AIM ETF
Minimum
Investment
$50,000
Pershing LLC
Dynamic
AIM ETF U.S. Focus
$50,000
Pershing LLC
Dynamic
AIM Hybrid
$25,000
Pershing LLC
Dynamic
AIM Index
Pershing LLC
$100/
$10,0003
Dynamic
AIM Index ETF
$50,000
Pershing LLC
Dynamic
$25,000
Pershing LLC
Dynamic
$100,000
Pershing LLC
Dynamic
$100,000
Pershing LLC
ETFs and mutual
funds
ETFs and mutual
funds
Mutual funds and
ETFs
Mutual funds and
ETFs (primarily
passively managed
funds, but actively
managed funds can
also be utilized)
ETFs and mutual
funds
ETFs and mutual
funds
Mutual funds, ETFs,
stocks and bonds
Mutual funds, ETFs,
stocks and bonds
N/A
N/A
AIM Risk-Managed
Equity5
Unified Wealth
Portfolio Dynamic
Unified Wealth
Portfolio Dynamic U.S.
Focus
CAAMS Stock
Managed Fixed Income
$50,000
$250,000
Pershing LLC
Pershing LLC
Stocks and ETFs
Customizable to
include corporate,
municipal, &
government debt,
ETFs, options, CDs
and stocks
¹ The Progressive Asset Management Program adds additional diversification to your portfolio as your account value meets higher
thresholds. For portfolios up to $25,000, your portfolio is managed using five asset class allocations; For portfolios between $25,000 and
$50,000, your portfolio is managed using eight asset class allocations; For portfolios between $50,000 and $100,000, your portfolio is
managed using twelve asset class allocations; For portfolios over $100,000, your portfolio is managed using fourteen or more asset class
allocations. Portfolios that subsequently fall below the investment minimum for a given asset class allocation will be moved down to the
asset allocation appropriate to the portfolio’s value. Lincoln Investment can change or add asset allocation thresholds at our sole
discretion.
² Progressive Asset Management ESG utilizes a uniform number of asset classes in portfolios for all account values over the investment
minimum.
3 Periodic Investment Plan minimum of $100 or $10,000 lump sum investment minimum.
4 See Item 8: Methods of Analysis, Investment Strategies and Risk of Loss for more information on Environmental, Social and
Governance (“ESG”) investing and our ESG model portfolios.
5 AIM Risk-Managed Equity utilizes buffer ETFs in its model portfolios. See Item 8: Methods of Analysis, Investment Strategies and
Risk of Loss for more information on risks associated with investing in buffer ETFs.
Select Manager Program
The Select Manager Program provides Lincoln Wealth Solutions investors with access to (i) model portfolios
supplied by third-party Model Providers comprised of mutual funds, ETFs, ETNs and/or equity securities, and (ii)
separately managed account portfolios managed by third-party Separate Account Managers, comprised of equity
securities, fixed income securities, mutual funds, ETFs, ETNs, options and/or cash. The Select Manager Program
provides Lincoln Workplace Retirement Solutions investors with access to model portfolios supplied by Model
Providers comprised of mutual funds and Eligible ETFs. The third-party Model Providers and Separate Account
Managers available within the Select Manager Program are referred to as Select Manager(s). Either the third-party
Separate Account Manager or Lincoln Investment on behalf of the third-party Model Provider will act with full
discretion to manage the assets allocated to the Select Manager Program, including purchases, sales, allocations,
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March 2026
reallocations, reinvestments or rebalances of the program assets, all without prior consent from or consultation with
you. Overlay Manager will act with Overlay Discretion with respect to model portfolios within the Select Manager
Program. Your chosen Select Manager provides ongoing monitoring for the model portfolio or Separate Account
portfolio within the Select Manager Program. Overlay Manager provides ongoing monitoring of model portfolio
implementation and coordination services for assets in the Select Manager Program.
Certain third-party Model Providers offered by Lincoln Investment do not charge Lincoln Investment for providing
model portfolios; instead, these model providers are compensated directly or indirectly by their affiliated mutual
funds that are utilized in their model portfolios.
Manager Fee - Standard Schedule¹
Assets
First $500,000
$500,000.01 - 1,000,000
$1,000,000.01 - 2,000,000
$2,000,000.01 – 5,000,000
$5,000,000.01 – 10,000,000
$10,000,000.01 – 20,000,000
$20,000,000.01 – 35,000,000
Over $35,000,000
Manager Fee
0.30%
0.28%
0.25%
0.23%
0.20%
0.19%
0.19%
0.19%
Manager Fee – BlackRock/Vanguard ETF Model
Portfolios²
Assets
First $500,000
$500,000.01 - 1,000,000
$1,000,000.01 - 2,000,000
$2,000,000.01 – 5,000,000
$5,000,000.01 – 10,000,000
$10,000,000.01 – 20,000,000
$20,000,000.01 – 35,000,000
Over $35,000,000
Manager Fee
0.15%
0.13%
0.10%
0.10%
0.10%
0.10%
0.10%
0.10%
¹ AAMA, BlackRock Target Allocation ESG ETF, Calvert Responsible, Capital Group ETF, CCMG/CCMG Global Risk Managed,
CRMC American Funds/American Funds Tax Aware, DoubleLine, Franklin Templeton, ICON, J.P. Morgan Global Multi Asset/J.P.
Morgan Tactical ETF, Meeder, PIMCO Fixed Income Tax Aware/PIMCO Fixed Income Taxable, Russell/Russell Tax Managed.
² BlackRock Target Allocation ETF, Vanguard ETF.
Select Manager Program Model Providers/Sub-Advisers
(Each Model Provider offers multiple risk level Model Portfolios)¹
Discipline
Model Provider
Investment Types
Custodian of Assets
Strategic
Minimum
Investment4
$10,000
Mutual Funds and ETFs
Pershing LLC
Strategic
Capital Research and
Management Company
(American Funds)
Russell Investments
$10,000
Mutual Funds and ETFs
Pershing LLC
Strategic
$50,000
ETFs
Pershing LLC
Dynamic
$10,000
Mutual Funds and ETFs
Pershing LLC
Dynamic
$50,000
ETFs
Pershing LLC
Dynamic
$25,000
Mutual Funds and ETFs
Pershing LLC
Dynamic
Mutual Funds and ETFs
Pershing LLC
$10,000/
$25,0003
Dynamic
Dynamic
$10,000
$10,000
Mutual Funds and ETFs
Mutual Funds and ETFs
Pershing LLC
Pershing LLC
Dynamic
Dynamic
$10,000
$25,000
Mutual Funds and ETFs
Mutual Funds and ETFs
Pershing LLC
Pershing LLC
Dynamic
$10,000
Mutual Funds and ETFs
Pershing LLC
Vanguard Advisers,
Inc.
Advanced Asset
Management Advisors,
Inc.
BlackRock Investment
Management, LLC
Calvert Research and
Management2
Clark Capital
Management Group
(CCMG)
DoubleLine Capital LP
Franklin Templeton
Investments
ICON Advisers, Inc.
J.P. Morgan Investment
Management Inc.
Meeder Advisory
Services, Inc.
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March 2026
Select Manager Program Model Providers/Sub-Advisers
(Each Model Provider offers multiple risk level Model Portfolios)¹
Discipline
Model Provider
Investment Types
Custodian of Assets
Dynamic
Minimum
Investment4
$25,000
Mutual Funds and ETFs
Pershing LLC
Pacific Investment
Management Company
(PIMCO)
1 Model portfolios are available only to residents of the United States.
2 See Item 8: Methods of Analysis, Investment Strategies and Risk of Loss for more information on Environmental, Social and
Governance (“ESG”) investing.
3 Investment minimum of $10,000 on Lincoln Workplace Retirement Solutions and $25,000 on Lincoln Wealth Solutions.
4 Investment minimums vary depending upon each Model Provider program offering. Certain programs can have a higher investment
minimum than shown above for each Model Provider. See your Investment Management Agreement.
Select Manager Program Separate Account Managers (SMA)
(Each Separate Account Manager offers multiple strategies)
Minimum Investment¹
Manager Fee²
Separate Account Manager
Davidson
Fiduciary Trust
Fort Washington
Haverford
One Capital
Thornburg
Todd
Uniplan
Wright
$250,000
$100,000
$1,000,000 to $5,000,000
$250,000
$500,000
$1,000,000
$1,000,000
$100,000
$200,000 to $250,000
0.25 – 0.30%
0.50%
0.20 – 0.55%
0.50%
0.65%
0.25%
0.50%
0.50%
0.50%
Custodian of Assets
Pershing LLC
Pershing LLC
Pershing LLC
Pershing LLC
Pershing LLC
Pershing LLC
Pershing LLC
Pershing LLC
Pershing LLC
¹ Minimum Investment varies by Select Manager and selected strategy. See your Investment Management Agreement.
² Manager Fee varies by Select Manager, selected strategy, and in some cases, investment amount. See your Investment Management
Agreement.
Manager Access Program
The Manager Access Program provides Lincoln Wealth Solutions investors with access to (i) model portfolios
supplied by third-party Model Providers comprised of mutual funds, ETFs, ETNs and/or equity securities, and (ii)
separately managed account portfolios managed by third-party Separate Account Managers, comprised of equity
securities, fixed income securities, mutual funds, ETFs, ETNs, options and/or cash. The Manager Access Program is
not available to Lincoln Workplace Retirement Solutions investors. Third-party Model Providers and Separate
Account Managers available within the Manager Access Program are referred to as “Access Manager(s)”. The
Access Manager will act with full discretion to manage the assets allocated to the Manager Access Program,
including purchases, sales, allocations, reallocations, reinvestments or rebalances of the program assets, all without
prior consent from or consultation with you. Overlay Manager will act with Overlay Discretion with respect to
model portfolios within the Manager Access Program. Your chosen Access Manager provides ongoing monitoring
of the model portfolio or Separate Account within the Manager Access Program. Overlay Manager provides
ongoing monitoring of model portfolio implementation and coordination services within the Manager Access
Program.
In addition to the Financial Advisor Fee, Platform Fee, and Manager Fee for your selected Access Manager, you will
pay an annual asset-based Sponsor Fee, as shown in the table below.
Sponsor Fee
Assets
First $500,000
$500,000.01 - 1,000,000
Over $1,000,000
Sponsor Fee
0.10%
0.07%
0.05%
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March 2026
Manager Fee varies by Access Manager, selected strategy or model portfolio, and in some cases, investment
amount. See the Investment Proposal provided by your Advisor for more information.
Unified Managed Account (UMA) Program
The Unified Managed Account (“UMA”) Program provides Lincoln Wealth Solutions and Lincoln Workplace
Retirement Solutions investors with access to two or more of the investment portfolios within or across the Client
Custom Portfolios, Premier Asset Management, Select Manager and, for non-403(b)/457(b) accounts, Manager
Access program, within a single UMA Account. Each Program investment portfolio within the UMA Account is
referred to as a “Sleeve.”
In the UMA Program, BNYMA is authorized to act as “UMA Overlay Manager” for your UMA Account. UMA
Overlay Manager has the same authorities granted to the Overlay Manager on non-UMA accounts, with the addition
of the authority to utilize Overlay Discretion to allocate and rebalance assets across the selected Program(s), Sleeve
Manager(s) (defined below), model portfolio(s), and investments in accordance with the trading parameters
established by the IM&R Team and the target Overlay Allocation established by your Advisor. Lincoln Investment
may change the UMA Overlay Manager at any time in its sole discretion to another unaffiliated investment adviser,
an affiliated investment adviser or Lincoln Investment may itself assume, replace or add to the responsibilities of the
UMA Overlay Manager, subject to providing notice to you.
Lincoln Investment, Select Manager and/or, for non-403(b)/457(b) accounts, Access Manager, as applicable
(“Sleeve Manager(s)”) is authorized to manage the assets allocated to each Sleeve Manager’s respective Sleeve with
“Full Discretion”, or the authority to manage the assets you have allocated to each respective Program including
purchases, sales, allocations, reallocations, reinvestments or rebalances, all without prior consent from or
consultation with you. The UMA Overlay Manager is authorized to act with Overlay Discretion with respect to
model portfolios within the UMA Program and your Overlay Allocation. Each of the Sleeve Managers provides
ongoing monitoring for its respective Sleeve(s). UMA Overlay Manager provides ongoing monitoring of model
portfolio implementation and coordination services within the UMA Program.
Your Advisor will provide investment advice to you regarding the percentage of your UMA Account to be allocated
to each Sleeve (the “Overlay Allocation”), including selection of Sleeve Manager(s), Model(s) and Separate
Account(s). You will make the ultimate decision regarding establishment and ongoing selection of an Overlay
Allocation, Sleeve Manager(s), model portfolio(s) and/or, for non-403(b)/457(b) accounts, Separate Account(s).
Your Advisor will provide investment advice to you regarding the percentage of your UMA Account to be allocated
the Client Custom Portfolios Program, if any. Your Advisor will provide investment advice to you regarding mutual
funds, ETFs, options, unit investment trusts (“UITs”), equity and fixed income securities, and alternative assets such
as business development companies (“BDCs”) and limited partnerships that are available in the Client Custom
Portfolios Sleeve(s). With regard to the Client Custom Portfolio Sleeve, if any, your Advisor has the authority to act
with Limited Discretion, which includes the authority to rebalance your account to a portfolio allocation
preauthorized by you, liquidate account assets to replenish the established sweep position or free credit balance, and
reallocate assets from your sweep position or free credit balance to an existing cash equivalent investment if the
balance in the sweep position or free credit balance has increased from the agreed upon target allocation or if the
anticipated debit balance has changed. Should you allocate assets to the Client Custom Portfolios Program, your
Advisor will make recommendations to you and you will make the ultimate decision regarding the purchase, sale, or
allocation of your assets in your Client Custom Portfolio Sleeve. Your Advisor will periodically monitor your Client
Custom Portfolios Sleeve(s), if any, and Overlay Allocation in the UMA Program. At least annually, your Advisor
will review your UMA Account to ensure the Overlay Allocation and any Client Custom Portfolios Sleeve(s) remain
consistent with your goals and objectives based upon information you provide. Client Custom Portfolios Sleeves
utilized within the UMA Program account are part of the UMA Wrap Fee Program. Accounts comprised solely of
the Client Custom Portfolios Program (non-UMA) are non-wrap and as such are described in our Form ADV Part
2A brochure.
In the UMA Program, your Advisor is authorized to act with “UMA Limited Discretion” which includes the
authority to rebalance to a portfolio allocation pre-authorized by you, for (i) the Overlay Allocation for your UMA
Account, and (ii) the Client Custom Portfolios Sleeve(s) in your UMA Account, if any; liquidate account assets to
replenish the established sweep position or free credit balance; and reallocate from your sweep position to an
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March 2026
existing cash equivalent investment if the balance in the Sweep Position or free credit balance has increased from
the agreed upon target allocation or if the anticipated debit balance has changed.
The target allocation of the investment portfolios you select applies at the time your UMA account is established.
UMA Overlay Manager will invest any additions of cash or securities to the UMA account in consideration of the
Overlay Allocation, and any withdrawals of cash or securities from the UMA Account may cause UMA Overlay
Manager to rebalance the existing investments in your UMA Account in consideration of the Overlay Allocation.
However, your actual asset allocation may not match the Overlay Allocation due to fluctuations in the market value
of the assets in your UMA account, as well as other factors.
If you select the UMA Program, in addition to the Financial Advisor Fee and Platform Fee, you will pay an annual
asset-based UMA Fee of 0.05% on all assets in the UMA account. In addition, you will pay a Manager Fee which
varies by the selected manager(s), selected strategy(ies) or model portfolio(s), and in some cases, investment
amount. Lincoln Wealth Solutions accounts will also pay a Sponsor Fee on any assets allocated to a Manager Access
Sleeve. See the Investment Proposal provided by your Advisor for more information.
Personal Portfolio Management (PPM) Program
The Personal Portfolio Management (“PPM”) Program provides you with access to (i) strategic or dynamic model
portfolios for which Lincoln Investment, acting as Model Provider, supplies asset class target allocations for each
available model portfolio and your Advisor performs investment selection from available investments for the PPM
Program (referred to as “Strategic Model Portfolios” and “Dynamic Model Portfolios”), and (ii) custom model
portfolios for which your Advisor supplies the asset class target allocation within limits set by Lincoln Investment
and performs investment selection from available investments for the PPM Program and in accordance with your
established risk level (“Custom Model Portfolios”). However, for the PPM Program, Lincoln Investment, as Model
Provider, will not be selecting the mutual funds or ETFs. BNYMA has the authority to decide which mutual funds
and ETFs are made available within the Personal Portfolio Management (PPM) Program. BNYMA or your Advisor
will select the mutual funds and ETFs from the available funds, depending upon the selected model portfolio.
The extent to which Lincoln Investment, your Advisor, and/or BNYMA have the authority to act with discretion in
the PPM Program depends on the model portfolio offering selected within the PPM Program, as outlined in your
investment advisory agreement. Advisors have the authority to change the model portfolio within the PPM Program
following the initial recommendation.
In addition to the Financial Advisor Fee and Platform Fee, you will pay an annual asset-based PPM Fee, as shown in
the table below.
PPM Fee
Assets
First $500,000
$500,000.01 - 1,000,000
$1,000,000.01 - $2,000,000
Over $2,000,000
PPM Fee
0.15%
0.13%
0.13%
0.12%
Other Wrap Fee Programs
Lincoln Investment sponsors and currently offers the following Wrap Fee Programs on third-party platforms.
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March 2026
Advisor Managed and Third-Party Managed Wrap Fee Programs and Fees
Discretionary
Program
Third Party
Adviser Fee
Minimum
Investment
Custodian
of Assets
Wrap Fee
Program
Name
Types of
Securities
Offered
Lincoln’s
Max. Wrap
Fee¹
1.25%
N/A
General
Securities
Charles
Schwab &
Co., Inc.
Depends on
platform and
individual
Advisor
Advisor
Managed
Program
(Model
Portfolios
and/or
Client
Custom
Portfolios)²
Varies - Your
Advisor can act with
discretionary
authority, but only if
he or she has been
(1) approved by
Lincoln Investment
for discretion; and
(2) authorized in
writing by you.
General
Securities
Pershing
LLC
Subject to
Third-party
money
manager’s
Minimum
GPS
Manager
Series
(Third-
Party
Managed)
Yes – Investor will
grant written
discretionary
authority to the
Third-party money
manager
Max Financial
Advisor Fee:
1.25%
Max Program
Sponsor Fee:
0.35%
Max Total
Lincoln Fee:
1.60%
You will be
assessed an
additional third-
party money
manager fee
which varies
depending on the
manager(s)
selected for your
portfolio.
General
Securities
Pershing
LLC
Subject to
Third-party
money
manager’s
Minimum
GPS
Allocation
Series
(Third-
Party
Managed)
Yes – Investor will
grant written
discretionary
authority to the
Third-party money
manager
Max Financial
Advisor Fee:
1.25%
Max Program
Sponsor Fee:
0.55%
Max Total
Lincoln Fee:
1.80%
You will be
assessed an
additional third-
party money
manager fee
which varies
depending on the
manager(s)
selected for your
portfolio.
1 Advisor fee is negotiable. The Annual Program Sponsor Fee is reduced further for assets over $500,000 as shown below.
² Available only to a limited number of Advisors.
Fees for Advisor Managed Program (Model Portfolios and/or Client Custom Portfolios)
Maximum Wrap Fee (including Financial Advisor Fee)
The Wrap Fee (including Financial Advisor Fee) is not to exceed 1.25% at
each fee tier.
Assets
First $500,000
Next $500,000
Next $1,000,000
Over $2,000,000
Fees for GPS Manager Series (Third Party Managed)
Assets
First $500,000
Next $500,000
Next $1,000,000
Over $2,000,000
Maximum Financial
Advisor Fee¹
1.25%
1.07%
0.89%
0.73%
Maximum Annual
Program Sponsor Fee
0.35%
0.30%
0.25%
0.25%
Maximum Total
Lincoln Fee²
1.60%
1.37%
1.14%
0.98%
¹ Certain Advisors are permitted to assess a higher fee than the Maximum Financial Advisor Fee shown above,
provided the Financial Advisor Fee does not exceed 1.25% at any tier.
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² You will be assessed a third-party money manager fee in addition to the Maximum Total fee shown above. This
additional fee varies depending on the manager(s) selected for your portfolio.
Fees for GPS Allocation Series (Third Party Managed)
Assets
First $500,000
Next $500,000
Next $1,000,000
Over $2,000,000
Maximum Financial
Advisor Fee¹
1.25%
1.07%
0.89%
0.73%
Maximum Annual
Program Sponsor Fee
0.55%
0.45%
0.45%
0.40%
Maximum Total
Lincoln Fee²
1.80%
1.52%
1.34%
1.13%
¹ Certain Advisors are permitted to assess a higher fee than the Maximum Financial Advisor Fee shown above,
provided the Financial Advisor Fee does not exceed 1.25% at any tier.
² You will be assessed a third-party money manager fee in addition to the Maximum Total Fee shown above. This
additional fee varies depending on the manager(s) selected for your portfolio.
Fees may be lower depending on many factors including, but not limited to, the amount of money invested in the
Wrap Fee Program. Ask your Advisor for the fee schedule tiers for these programs.
When you select certain advisory programs and/or platforms, Lincoln Investment earns additional fees. For example,
Lincoln Investment earns a Manager Fee when you select advisory programs professionally managed by IM&R.
Lincoln Investment has a financial incentive to promote these advisory programs and/or platforms to generate
additional revenue.
Advisor Managed Wrap Fee Program
Your Advisor’s role is to earn and maintain a relationship with you to provide you financial and life planning
consultation, as needed by you, as well as investment advice services which include assisting you in the
determination of the appropriate investment advisory investments and/or advisory programs for you, conversing
with you on an as-needed or as requested basis, to ensure that the investments and programs continue to meet your
stated objectives and needs. Some advisors may also provide supplemental reports on a periodic basis to assist you
in evaluating the effectiveness of the investments and advisory program(s). Advisors provide either periodic or
ongoing investment advice to their clients, and certain approved Advisors provide ongoing and continuous
discretionary portfolio management to their clients. Either way, your Advisor has the responsibility to make
recommendations or select securities based on your needs and objectives. All advice is geared to meet your risk
tolerance, income, any investment restrictions, and tax management objectives, if applicable. Portfolio investments
in this program typically include ETFs and mutual funds, but may also include other securities such as individual
stocks, bonds, ETNs or options.
For those Advisors who have been granted the authority to manage accounts on a discretionary basis, discretionary
authority may be exercised within an Advisor Managed Model Portfolio, where your account is managed to the
stated objectives of the portfolio, or Client Custom Portfolios, a custom advisor managed portfolio constructed and
managed to meet your specific objectives.
Third-Party Managed Wrap Fee Program
Lincoln Investment may also act as Co-Adviser to introduce you to a third-party money manager in order to provide
you with certain unique investment advisory services tailored to your needs. Neither Lincoln Investment nor your
Advisor performs the ongoing discretionary asset management in these portfolios; this is provided by the third-party
money manager. As Co-Adviser, Lincoln Investment and your Advisor are responsible to work with you to collect
all necessary information and documentation to assist you in selecting the appropriate investment strategy offered by
the third-party money manager and to answer any questions you may have about the money manager or managed
portfolio(s).
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Additional Information Regarding Wrap Program Fees
The Wrap Fee Programs described above may cost more or less than if you were to purchase such services
separately. Certain factors, such as trading frequency, can impact the cost effectiveness of such Wrap Fee Programs.
Generally, in an account where there is infrequent trading, a regular brokerage account incurring transaction fees
along with the separate purchase of such investment advice for a fee may be less expensive.
The Wrap Fee may cover various services rendered and costs incurred under the selected program including client-
advisor consultations, transaction-related costs, investment management, and performance reporting. However,
securities transactions executed in your program account(s) may also include mark-ups, markdowns or dealer
spreads paid to market makers or other principals from whom securities were obtained. These mark-ups, markdowns
or dealer spreads will be retained by the market maker or other principal and will not be credited or reimbursed to
your account or to Lincoln Investment. In addition, the Wrap Fee will not cover fees for trades executed away from
the custodian which will be retained by the executing firm and will not be credited or reimbursed to your account or
to Lincoln Investment.
For the majority of Wrap Programs offered by Lincoln Investment, your Wrap Fee will be assessed on a monthly
basis in advance of services rendered and will be based on the account value on the last business day of the prior
month. The specific manner in which advisory fees are calculated and charged can vary depending upon the
advisory program you select. See your investment advisory agreement with Lincoln Investment for billing details
applicable to your advisory program. In your investment advisory agreement, you must also authorize Lincoln
Investment to directly debit advisory fees from your account. Advisory fees are in most cases automatically
deducted on a monthly basis in advance from cash/money market positions or by liquidating assets held within the
account. Lincoln Investment can waive or negotiate advisory fees at our sole discretion. For assets held on the
Pershing platform, Lincoln does not assess (1) pro-rata fees for deposits or (2) pro-rata refunds for withdrawals, but
will assess a pro-rata fee for accounts opened during the month and issue pro-rata refunds for terminations. See your
investment advisory agreement for pro-rata fee assessments and refunds thresholds as these vary by platform and
program.
In general, a client may terminate Lincoln Investment’s or its Advisor’s advisory services at any time upon written notice
to us. For assets held on the Pershing platform, Lincoln Investment’s receipt of notice of your death will immediately
terminate all advisory services. Account assets will be frozen until such time as new trading instructions are received from
the authorized executor for the estate of the deceased or a designated beneficiary to the account. Clients remain responsible
to pay fees for services performed but not yet billed.
For assets held on platforms other than Pershing, see your investment advisory agreement for billing details,
including the frequency of fees assessment, whether your fee is assessed in advance or arrears of services rendered,
and any applicable thresholds for inception billing, termination billing, and initial and interim billing on deposits and
withdrawals as these can vary by platform and program. Threshold levels for initial and interim billing for deposits
and withdrawals can vary based on platform and program.
You could purchase products or services similar to those offered by Lincoln Investment separately from our
affiliated investment adviser, Capital Analysts, LLC or from any financial services provider. Lincoln Investment
offers some employer sponsored retirement plans, current and former employees, its Advisors, and family members
a discount or waiver of some or all fees. Lincoln Investment can waive or negotiate fees at our sole discretion.
Other Costs That You May Incur
Wrap Fees, and other costs associated with your portfolio, impact the overall performance of your portfolio. It is
important to review and consider these costs when making your advisory and investment decisions.
Costs may include the following:
1. Mutual Fund 12b-1 Distribution Fees. An expense within some mutual fund share class offerings is a
Mutual Fund Distribution Fee, also called a 12b-1 fee, which is paid to your broker-dealer. For all Lincoln
Investment advisory accounts on Pershing’s platform, when Lincoln Investment is the introducing broker-
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dealer on your advisory account and where the 12b-1 fee is paid to Lincoln Investment, we have instructed
Pershing to directly refund this fee to your account. You may still incur a 12b-1 fee expense for any portion
of the 12b-1 fee expense that the fund does not share with Pershing or that Pershing does not share with
Lincoln Investment. This crediting of 12b-1 fees will alleviate the conflict of interest associated with
Lincoln Investment receiving this third-party compensation and will also reduce the expense to you
associated with purchasing a mutual fund share class which includes a 12b-1 fee expense. Whether you
receive and the manner in which you receive this credit depends on the platform where your advisory assets
are held.
2. Internal Expenses. Internal management fees and other fund fees and expenses charged by the mutual
fund or sub-account of a variable annuity (also known as the internal expense). All mutual funds, ETFs,
insurance and annuity companies charge a fee for the management and operations of their offerings. Higher
internal expenses can adversely affect the long-term performance of your portfolio when compared to share
classes of the same fund that assess lower internal expenses. For more complete information regarding the
internal expenses of an investment and how they impact your costs and performance, you should read
“Understanding Share Classes within your Investment Advisory Accounts” below.
3. Platform Fees. Lincoln Investment offers its advisory services on various broker-dealer platforms. Each
platform assesses different account fees, such as platform fees, ticket charges, commissions, wire fees,
trade-away fees, statement and confirmation fees, retirement plan recordkeeping or custodial fees, and low
balance or account termination fees. Depending on the platform/custodian selected, some fees can be
avoided or reduced. For instance, applicable fees will be different for an account opened on Pershing’s
platform versus another third-party platform/custodian. Platforms/custodians can waive or negotiate their
respective fees assessed to you, Lincoln Investment, and/or your Advisor, in each platform/custodian's sole
discretion. For a description of trading and administrative fees associated with where your account will be
held, view the specific platform disclosure documents for your account found at
www.lincolninvestment.com/Disclosures. Also, please refer to Item 12: Brokerage Practices for further
information.
4. Mutual Fund Surcharge Fees. Some custodians and platforms assess a surcharge fee for transactions in
certain mutual fund share classes, typically to offset the costs of providing services when the mutual fund
does not pay the custodian or platform directly.
5. Mutual Fund Short-Term Trading Redemption Fees. Some mutual funds impose short-term trading
redemption fees of up to 2% for active trading or exchanging in and out of their funds. This could affect
you or the ability of Lincoln Investment, your Advisor or third-party manager to properly manage your
portfolio as these costs will impact the performance of your portfolio or may be an incentive not to trade.
6. Variable Annuity Rider and Contract Costs. These costs may include, but are not limited to, annual base
annuity contract charges, optional benefit riders, underlying sub-account fees and expenses, and potential
surrender fees.
7. Retirement Plan Rollovers. If you decide to roll assets out of a retirement plan, such as a 401(k) plan, into
an individual retirement account ("IRA"), we have a financial incentive to recommend that you invest those
assets with us because we will be paid an advisory fee on those assets, and other compensation. You should
be aware that such fees would likely be higher than those you would pay through the plan, and there can be
additional costs and expenses, such as custodial fees and account fees. As securities held in a retirement
plan are generally not transferred to an IRA, commissions and sales charges may be charged when
liquidating such securities prior to the transfer, in addition to commissions and sales charges previously
paid on transactions in the plan. For more information about rollovers, see The Lincoln Investment
Companies Investor Agreement and Disclosure Handbook.
You could incur additional charges imposed by custodians, broker-dealers, investment and insurance companies and
other third parties, such as transfer taxes, wire transfer and electronic fund fees and other fees and taxes on
brokerage accounts and securities transactions. Such charges and fees are exclusive of and in addition to Lincoln
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Investment’s fee. You shall be responsible for payment of any and all taxes that may be due as a result of any
transactions in your account.
Other Compensation to Lincoln Investment and Our Conflicts of Interest
Lincoln Investment recognizes its fiduciary responsibility to place your interests above ours and that other
compensation received by us, or an affiliate, from other sources presents a conflict of interest and could be looked
upon by you as an incentive for us to recommend investment products or advisory services based on compensation
rather than on your financial needs. Below is a description of conflicts of interest that we have identified in the
conduct of our business that we believe may be material. With many of these conflicts, we have taken steps to
mitigate or reduce the conflict.
Understanding Share Classes in Lincoln Investment Advisory Accounts
Mutual funds are common investments for individuals. A mutual fund pools money from many investors and invests
the money in securities or other assets. A mutual fund has various expenses that are paid from fund assets. These
internal expenses are reflected in the fund's "expense ratio." Such expenses include fees paid to the adviser that
manages the fund, operational expenses, and fees paid to the brokers that sell shares of, and provide services to, the
fund. These are ongoing fees and expenses charged throughout the life of the mutual fund investment. Fees and
expenses are an important consideration in selecting a mutual fund because these charges lower an investor's returns.
A mutual fund frequently offers investors different "share classes." Each class will invest in the same "pool" or
portfolio of securities and other assets, but each class will have different fees and expenses and, therefore, different
returns. For example, some share classes have higher expense ratios because they pay brokers more for selling or
servicing that particular share class. In contrast, other share classes of the same fund may have lower internal fees
and expenses. A single mutual fund will often have share classes with different expense ratios, with the share classes
that have higher expense ratios generally having lower returns than share classes with lower expense ratios. In other
words, an individual investor may pay more, or less, for precisely the same mutual fund investment, depending on
the share class. These internal fees and expenses are in addition to any fees a broker may directly charge customers
on particular share classes, including transaction-related fees, such as surcharge fees, at the time of buying or selling
the fund shares, and are in addition to the investment advisory fee you will pay.
The expense ratio of a fund is disclosed in the fund’s prospectus and annual reports and generally reflects the annual
operating costs of the fund, assessed as a percentage of a fund’s average assets. The expense ratio within a mutual
fund share class can fluctuate from what is shown in a prospectus for the fund offering and annual report and can
vary over time and from year to year. A fund that was deemed to have a lower expense ratio at the time of purchase
may not actually maintain that expense ratio during the time that the fund is held and new fund share classes may
become available with different expense ratios.
Lincoln Investment looks at the “Prospectus Net Expense Ratio” as provided by a third-party data provider for each
mutual fund share class to determine the least expensive eligible share class. The Prospectus Net Expense Ratio is a
fund’s stated total annual operating expense percentage after any contractual fee waivers or other expense
reimbursements to the fund.
Lincoln Investment’s Share Class Selection Policy for Advisory Accounts
This share class selection policy applies to your advisory assets that are custodied at Pershing LLC (“Pershing”) and
for which Lincoln Investment and/or your financial professional initiate the trade and is described below. For your
advisory assets custodied at Pershing utilizing an overlay manager, the share class designated by Lincoln Investment
is subject to the approval of your overlay manager. The overlay manager can choose to utilize a share class in your
account that differs from the policy outlined below. If applicable, please see your overlay manager’s Form ADV 2A
and/or Appendix I for additional details.
Although you are purchasing at net asset value of the fund, there are internal expenses built into every mutual fund
that can impact the performance of your investment over time. Regardless of whether you have selected a
discretionary or non-discretionary advisory program, share class selection for your mutual fund purchases within
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your advisory account will be determined by Lincoln Investment. Share class expenses can vary across different
share classes of the same fund. In furtherance of its fiduciary duty to advisory clients, Lincoln Investment will seek
to select the least expensive share class available on the applicable custodial platform for the selected mutual fund
for which all of our retail advisory accounts will be eligible (except that money market mutual funds within the
Sweep Program and 403(b)7/457(b) accounts are treated differently, each as described below). For purposes of this
policy, the least expensive share class is defined as the share class of a mutual fund that has the lowest prospectus
net expense ratio as published by the third-party data provider (or a share class with a net expense ratio that is no
greater than ten basis points (0.10%) different than such share class with the lowest net expense ratio), subject to the
share classes’ investment minimums being appropriate for all of our retail advisory investors, obtaining investment
minimum waivers where they are available, and selecting a share class that is available to all investors regardless of
account tax type. In addition, due to specific mutual fund company constraints, situations will arise where Lincoln
Investment chooses a share class that does not have the lowest prospectus net expense ratio in that mutual fund in
order to remain consistent with the share classes of other mutual funds within a particular fund family available on
our platform.
Accounts on the Lincoln Workplace Retirement Solutions platform for 403(b)/457 accounts custodied at Pershing in
the Client Custom Portfolios (advisor-managed) program are subject to a No Surcharge Fund First (“NSFF”) policy,
as described below. The No Surcharge Fund First (“NSFF”) policy is applicable to Client Custom Portfolios
(advisor-managed) 403(b)/457(b) accounts only. Under the NSFF policy, for fund families that offer certain share
classes that assess a surcharge, Lincoln Investment will make available the share class with the least expensive
internal expense ratio that does not assess a surcharge fee. If the fund family does not offer a share class without a
surcharge fee, Lincoln Investment will make available the share class with the least expensive internal expense ratio
and the surcharge fee will be assessed. Generally, and subject to additional conditions, the designated share class
will be ascertained by designating the share class with the lowest internal expense ratio for which no surcharge fee
applies and all 403(b)/457(b) accounts on the Pershing platform will be eligible. Where all share classes of a mutual
fund assess a surcharge fee, that surcharge fee fund will remain available subject to the surcharge fee discussed
above and in the Lincoln Investment Trading Fees, Account Service Fees and Disclosures – Accounts Held on
Pershing Platform.
In addition to the share class selection factors described above, Lincoln Investment will also consider various other
factors when considering share class conversions in your advisory accounts, including but not limited to, whether
the fund will allow tax-free conversions, as well as whether there is a ten basis point (0.10%) or greater difference in
the expense ratio between the existing share class and the new, proposed share class. The fund share class used in a
discretionary Lincoln Investment Managed Model Portfolio can be different than the fund share class used in other
Lincoln Investment advisory accounts, including accounts managed by your financial professional, as a fund
minimum waiver may be available for discretionary Lincoln Investment managed model portfolios but not for other
types of advisory accounts, such as accounts managed by your financial professional. Most mutual funds offer
varying share classes, but all custodians may not make all share classes of a mutual fund available; therefore, the
designated share class selected by Lincoln Investment will likely vary across custodial platforms.
If the fund and share class selected includes a 12b-1 fee, Lincoln Investment will continue to credit back to your
advisory account any 12b-1 fee revenue received by the firm on behalf of your advisory assets to eliminate the
conflict of interest associated with the receipt of such revenue.
Lincoln Investment will review available mutual fund share classes periodically to identify share classes that must
be changed in order to align with this policy. If a different share class is identified that meets our policy criteria as
described herein, Lincoln Investment will initiate a share class conversion for all mutual fund investments in those
share classes. In addition, for accounts subject to the NSFF policy, if it is determined that a mutual fund share class
that does not assess a surcharge fee is available and meets our policy criteria as described above, Lincoln Investment
will initiate a share class conversion for all mutual fund investments in the surcharge fee share class to that no
surcharge fee share class (except that money market mutual funds within the Sweep Program are treated differently,
as described below). Share class conversions will appear on your account statements. The ability and length of time
to affect a share class conversion will vary and is subject to prospectus requirements and custodial platform
approval. If you transfer-in shares of a mutual fund into an advisory account that are in a share class with a lower
internal expense ratio than the share class available in your advisory program, Lincoln Investment can convert your
mutual fund position to the share class of that fund that meets our policy criteria as described herein (including a
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share class with a higher internal expense ratio). Lincoln Investment can also restrict additional purchases of a share
class and convert any grandfathered share class during a periodic review. For accounts subject to the NSFF policy, if
you transfer-in shares of a mutual fund that assesses a surcharge fee, Lincoln Investment will convert your mutual
fund position from a mutual fund share class that assesses a surcharge fee to a share class that does not assess a
surcharge fee, if available.
Not all mutual funds and share classes available to the investing public will be available to Lincoln Investment
and/or available for use in your advisory program. You should not assume that you are or will be invested in the
least expensive share class available, and the share class of a mutual fund offered by Lincoln Investment can have
higher expenses, and therefore lower returns. Additionally, Lincoln Investment has selected a higher-cost share class
with respect to the Dreyfus Government Cash Management Fund – Service Shares Sweep Product, which is the
designated sweep product for non-ERISA 403(b)7 and 457(b) plans and participant accounts and the designated
secondary sweep product for excess balances in the Dreyfus Insured Deposits L Sweep Product. There are less
expensive share classes of the same money market mutual fund available that would not provide revenue sharing
with the firm or would provide lesser amounts of revenue sharing with the firm.
Information about the mutual funds and share classes that are available through your account, including their
investment policies, restrictions, charges and expenses, is contained in the mutual funds’ prospectuses. You should
read these prospectuses carefully.
Third-Party Payments and Revenue Sharing from Pershing
In our role as introducing broker-dealer for assets held at Pershing, Pershing provides credits, payments and benefits,
including but not limited to fee and expense reductions, that incentivize us to recommend and continue to use
Pershing as clearing firm and custodian and achieve agreed upon asset levels in The Bank of New York Mellon
Corporation (“BNY”)’s affiliated products and services. Pershing and BNY Mellon Advisors, Inc. (“BNYMA”) are
affiliates of BNY.
Pershing Revenue Sharing, Payments and/or Expense Credits with Lincoln Investment. For accounts held
on Pershing’s platform, Pershing provides certain credits and payments to Lincoln Investment, as introducing
broker-dealer, pursuant to a written agreement in consideration of the extension and/or continuation of Lincoln
Investment’s current agreement with Pershing. Lincoln Investment does not refund or offset these
credits/payments against fees paid by clients. This revenue does not vary with respect to the investment
choices/recommendations made in your Pershing account. Overall, the expense credits received by Lincoln
Investment from Pershing for 2025 as allocated to the firm and its affiliates represented less than one percent of
Lincoln Investment’s total advisory revenue, less than one percent of Capital Analysts’ revenue and less than one
percent of Lincoln Investment’s broker-dealer revenue. The receipt of these expense credits and payments create
a conflict of interest to Lincoln Investment to recommend and/or use Pershing as a custodian over other
custodians that do not share these fees, do not provide expense credits/payments to us or that would share lesser
amounts with us. Additionally, under our agreement with Pershing, there is a termination fee schedule with
amounts that decrease over time. Therefore, Lincoln Investment has an incentive to maintain the relationship
with Pershing for a longer period of time. We mitigate these conflicts by disclosing them to you and by not
sharing the credits/payments with your Advisor.
Pershing Margin Participation. For advisory and brokerage accounts held on Pershing’s platform, Lincoln
Investment, as introducing broker-dealer, marks up the base interest rate pursuant to a written agreement with
Pershing, resulting in a higher margin interest rate to you. This mark-up will not exceed 2.25% above the base
interest rate. The receipt of revenue sharing with Pershing creates a conflict of interest to Lincoln Investment to
use Pershing as custodian over other custodians that do not permit us to mark-up the fees or limit the amount.
Lincoln Investment mitigates this conflict by disclosing it to you and by not sharing it with your Advisor.
Pershing Non-Purpose Loan Markups. For advisory and brokerage accounts held on Pershing’s platform,
Lincoln Investment, as introducing broker-dealer, marks up the base interest rate pursuant to a written agreement
with Pershing, resulting in a higher non-purpose loan interest rate to you. This mark-up will not exceed 0.75%
above the base interest rate. The receipt of revenue sharing with Pershing creates a conflict of interest to Lincoln
Investment to use Pershing as custodian over other custodians that do not permit us to mark-up the fees or limit
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the amount. Lincoln Investment mitigates this conflict by disclosing it to you and by not sharing it with your
Advisor.
Trading and Account Service Fees. Lincoln Investment establishes brokerage commission schedules for its
advisory and brokerage accounts. For accounts held on Pershing’s platform for which Lincoln Investment is
introducing broker-dealer (i) Pershing charges trading and account service fees for which Lincoln Investment, as
introducing broker-dealer, has added a mark-up that ranges from 0% to 420%; (ii) For certain trading and
account services for which Pershing does not assess a fee to Lincoln investment, Pershing permits Lincoln
Investment, as introducing broker-dealer, to impose its own fee which is charged to you. The receipt of these
fees creates a conflict of interest for Lincoln Investment since it creates an incentive for Lincoln Investment to
continue to use Pershing as custodian over other custodians that do not permit us to mark-up the trading and
account service fees or would limit the amount, or that would not permit us to set our own fee. We mitigate these
conflicts by disclosing them to you and by not sharing the mark-ups and Lincoln Investment fees with your
Advisor. Your Advisor is permitted to pay certain fees on your behalf in their sole discretion.
Growth Incentive Credits/Payments. For accounts opened and/or assets moved to Pershing by Lincoln
Investment or its affiliate, Capital Analysts, Pershing provides a credit/payment to Lincoln Investment based on
the total asset value of such accounts when the accounts are opened on Pershing, or accounts/assets are moved to
Pershing or retained by Pershing, pursuant to a written agreement with Pershing. The receipt of these
credits/payments creates a conflict of interest to Lincoln Investment and its affiliate, Capital Analysts, to
recommend and/or use Pershing as a custodian over other custodians that do not share these fees, do not provide
credits/payments to us or that would share lesser amounts with us. This revenue is not shared with your Advisor.
Acquisition Financial Support Credits/Payments. For accounts acquired from other firms by Lincoln
Investment or its affiliate, Capital Analysts, Pershing provides a credit/payment to Lincoln Investment based on
the total asset value of such accounts when they will be moved to Pershing or retained by Pershing, pursuant to a
written agreement with Pershing. The credit/payment provided to Lincoln Investment is greater for acquired
accounts that will be moved to Pershing compared to the credit for acquired accounts that will be retained by
Pershing (accounts already existing on Pershing’s platform). The receipt of these credits/payments creates a
conflict of interest to Lincoln Investment and its affiliate, Capital Analysts, to recommend and/or use Pershing as
a custodian over other custodians that do not share these fees, do not provide credits/payments to us or that
would share lesser amounts with us. This revenue is not shared with your Advisor.
The Lincoln Investment Companies Sweep Program. The Lincoln Investment Companies offer a sweep
program (“Sweep Program”) under which uninvested cash or “free credit balances” in your eligible accounts that
are custodied with Pershing are automatically invested or deposited (“swept”) into money market mutual fund(s)
(“Money Fund Sweep Products”), or bank deposit sweep product(s) eligible for FDIC insurance protection up to
$2.5 million (“Bank Deposit Sweep Products”) (collectively referred to as “Sweep Product(s)”), which consist of
interest-bearing bank deposit accounts (“Deposit Accounts”) at Federal Deposit Insurance Corporation (“FDIC”)
member banks. The member banks (“Program Banks”) can include The Bank of New York Mellon (“BNY”) and
BNY Mellon, N.A., banking affiliates of Pershing or other banking affiliates of Pershing. When participating in
the Sweep Program, you appoint Pershing as your authorized agent to establish and maintain Deposit Accounts
at various Program Banks. The Bank Deposit Sweep Products and Money Fund Sweep Products are supported
and operated through a private labelling arrangement with Dreyfus, a division of Mellon Investments
Corporation (“MIC”) and are available only to clients of broker-dealers who clear through Pershing, such as
Lincoln Investment. Pershing has appointed a third-party service provider IntraFi Network LLC (“IntraFi” or
“Administrator”), BNY Mellon Securities Corporation (“BNYSC”) and Dreyfus to provide certain services with
respect to the operation of the Deposit Accounts. MIC is a registered investment adviser and BNYSC is a broker-
dealer. BNY Mellon Investment Adviser, Inc. (“BNYIA” or “Adviser”) acts as investment adviser for the
Dreyfus Money Fund Sweep Products. Affiliates of BNY include but are not limited to, Pershing, BNYSC, MIC,
BNYIA, and BNY Mellon, N.A. BNY Mellon is the corporate brand for The Bank of New York Mellon
Corporation. For the most up-to-date information, see the applicable product-specific disclosure for a list of
BNY Mellon affiliates and their role in the operation of the Sweep Products.
Depending upon your account type, Lincoln Investment will designate a Sweep Product for use in your account.
Lincoln Investment offers two Bank Deposit Sweep Programs, the Dreyfus Insured Deposits L (“Tiered Rate
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Sweep Product”) and the Dreyfus Insured Deposits LV (“Level Fee Sweep Product”), and two Money Fund
Sweep Products, the Dreyfus Government Cash Management Fund Service Shares Sweep Product (Ticker
symbol DGUXX) and the Dreyfus Government Cash Management Fund Investor Shares Sweep Product (Ticker
symbol DGVXX). Each of these Sweep Products except for the Dreyfus Government Cash Management Fund
Investor Shares, offered only to ERISA accounts and as the secondary Sweep Product for balances over
$2,490,000 in the Level Fee Sweep Product, creates financial benefits and conflicts for us as described below.
Lincoln Investment has designated the Dreyfus Government Cash Management Fund Service Shares for non-
ERISA 403(b)7 and 457(b) plans and participant accounts and as the secondary Sweep Product for balances in
excess of $2,490,000 in the Tiered Rate Sweep Product. Lincoln Investment has designated the Tiered Rate
Sweep Product for use in commission-based individual retirement accounts (IRAs) and most non-retirement
brokerage and advisory accounts, and has designated the Level Fee Sweep Product for use in advisory IRAs.
Lincoln Investment receives a portion of the fee paid to Pershing by the Program Banks in connection with the
Bank Deposit Sweep Products and receives distribution assistance payments from Pershing in connection with
the Dreyfus Government Cash Management Fund Service Shares Sweep Product. Accordingly, Lincoln
Investment has a conflict of interest in that we have a financial incentive to designate the Tiered Rate Sweep
Product, the Level Fee Sweep Product and/or the Dreyfus Government Cash Management Fund Service Shares
Sweep Product as the Sweep Product(s) for your account and, for discretionary advisory programs managed by
Lincoln Investment, Lincoln Investment can allocate a portion of assets to the Sweep Product, each of which
generates additional revenue to us. This compensation is a significant source of revenue for Lincoln Investment
and Pershing. Pershing, other financial services firms and third parties could offer the same or similar money
market mutual fund sweep products and/or bank deposit sweep products, at a lower overall cost and higher
return to the investor than is available through the Sweep Program, whether directly through the provider or
through a sweep program offered by a different financial services firm. This receipt of revenue sharing from
Pershing creates a conflict of interest to Lincoln Investment to use Pershing as a custodian over other custodians
that do not share these fees, do not share these payments or that would share lesser amounts or that would not
permit us to set our own fee, to offer the Sweep Products and to recommend that you utilize the Sweep Products.
Lincoln Investment receives a greater financial benefit when cash is swept into the above Bank Deposit Sweep
Products and Money Fund Sweep Product than it otherwise would if your cash balance is held elsewhere, and
any compensation the firm receives reduces the interest and/or dividend you receive, and your overall investment
return. This compensation is retained by the firm and is not shared with you. Lincoln Investment receives greater
compensation as assets and/or accounts utilizing the Sweep Products increase, as more fully described below.
The Sweep Product fees that we receive are in addition to any investment advisory fees that you pay to Lincoln
Investment and your Advisor. This means that Lincoln Investment earns two layers of fees on the same Sweep
Product balances in your account, which can result in you experiencing a negative overall investment return. We
also receive different fees based on the Sweep Product designated for your account. Therefore, we have an
incentive for you to use (and invest your assets in) the sweep products that increase our compensation. If you
desire to maintain a cash balance in your account for an extended period of time awaiting investment and/or seek
the highest yields currently available in the market for your cash balance, please contact your Advisor or Lincoln
Investment for options outside of the Sweep Products. In order to mitigate these conflicts, Lincoln Investment
does not share this revenue with your Advisor. Your Advisor has the ability to waive the advisory fee on all
Sweep Products, should you request it.
Lincoln Investment has designated the Tiered Rate Sweep Product for use in commission-based IRAs and most
non-retirement brokerage and advisory accounts, and has designated the Level Fee Sweep Product for use in
advisory IRAs. Bank Deposit Sweep Products are an important source of significant revenue for Lincoln
Investment, Pershing, and Pershing’s affiliated Program Banks that participate in the Sweep Program. For
additional information regarding Pershing’s and their affiliates’ conflicts of interest, please see the link to our
Disclosures web page, included below. Lincoln Investment receives a portion of the fee paid to Pershing by the
Program Banks. Lincoln Investment sets the amount of the fee it receives from Pershing on your Bank Deposit
Sweep Product accounts and/or assets. This is a conflict of interest as it permits Lincoln Investment to assess a
higher fee to you in order to increase our revenue. Pershing offers other sweep products for which no
remuneration or less remuneration would be paid to Lincoln Investment, as introducing broker-dealer. The
portion of the fee received by us on the Bank Deposit Sweep Products is greater than the yield that you will
receive. Amounts paid to Lincoln Investment, Pershing and the Administrator reduce the interest rate paid on
your Bank Deposit Sweep Product balance. Therefore, the higher the compensation paid to us, the lower the
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interest paid to you; the lower the compensation paid to us, the higher the interest paid to you. You should
understand that this can result in you experiencing a negative overall investment return with respect to your
balance in the Bank Deposit Sweep Product. Additionally, bank deposit sweep products typically yield lower
returns than money market mutual funds. However, because Lincoln Investment earns a higher fee when you
invest in Bank Deposit Sweep Products than if you invest in other money market products such as money market
mutual funds, within or outside of the Sweep Program, Lincoln Investment is incentivized to designate Bank
Deposit Sweep Products for your account(s). Lincoln Investment receives greater compensation related to Bank
Deposit Sweep Products as the amount of assets and/or accounts utilizing the Sweep Products increase and can
take up to 6.00% of the interest rate paid on the balances of your Deposit Accounts. For additional information
on Lincoln Investment’s current fees and compensation earned in relation to the Sweep Program, see the link to
our Disclosures web page, included below. Accordingly, these arrangements present a conflict of interest to
Lincoln Investment because they provide an incentive for us to offer the Bank Deposit Sweep Products as our
default sweep products, to maintain balances in the Bank Deposit Sweep Products over other investment options,
including money market mutual funds, and for us and your Advisor to recommend that you enroll in and utilize
the Bank Deposit Sweep Products. For Bank Deposit Sweep Products balances in excess of $2,490,000, Lincoln
Investment has designated a secondary Money Market Sweep Product. For the Tiered Rate Sweep Product, the
secondary Money Market Sweep Product is Dreyfus Government Cash Management Fund Service Shares
(Ticker symbol DGUXX). If your excess balance is swept into Dreyfus Government Cash Management Fund
Service Shares, Lincoln Investment will earn fees on that balance, as further discussed below. For the Level Fee
Sweep Product, the secondary Money Market Sweep Product is Dreyfus Government Cash Management Fund
Investor Shares (Ticker symbol DGVXX). For additional information regarding these secondary Sweep
Products, please see the link to our Disclosures web page, included below. Program Banks do not have a duty to
offer the highest rates available or rates that are comparable to money market mutual funds or those offered by
other depository institutions or deposits held at Program Banks outside of the Sweep Program. The receipt of
revenue sharing from Pershing and the ability for Lincoln Investment to set its fee for the Sweep Products
creates a conflict of interest for Lincoln Investment to use Pershing as a custodian and to offer the Bank Deposit
Sweep Products we make available to you over other custodians or sweep products that do not pay a portion of
their fees to us (share revenue), share lesser amounts, or that do not permit the introducing broker-dealer to set
the fee it will assess for the Sweep Products.
Lincoln Investment has designated the Dreyfus Government Cash Management Fund Service Shares for non-
ERISA 403(b)7 and 457(b) plans and participant accounts and as the secondary Sweep Product for balances in
excess of $2,490,000 in the Tiered Rate Sweep Product, and Dreyfus Government Cash Management Fund
Investor Shares Sweep Product for ERISA accounts and as the secondary Sweep Product for balances in excess
of $2,490,000 in the Level Fee Sweep Product.
A Money Fund Sweep Product earns dividends, interest and other income from its investment, and distributes
this income (less expenses) to shareholders as dividends. For the Dreyfus Government Cash Management Fund
Service Shares Sweep Product, Lincoln Investment utilizes a share class that provides remuneration to us
(distribution assistance) which reduces the dividend you receive, even though other share classes are available to
Lincoln Investment that would pay Lincoln Investment less and you more. Lincoln Investment receives
distribution assistance from Pershing in the form of annual compensation of up to 0.55% for assets in the
Dreyfus Government Cash Management Fund Service Shares Sweep Product. This is not the least expensive
share class of the Dreyfus Government Cash Management Fund available or the least expensive share class
available through Pershing. Lincoln Investment utilizes a higher expense share class over other less expensive
share classes that would otherwise be available and of lower cost to you. There are less expensive share classes
of the same money market mutual fund available that would not provide revenue sharing with Lincoln
Investment or would provide lesser amounts of revenue sharing to us. Share classes with higher expenses can
lower your returns over time. This receipt of revenue sharing from Pershing creates a conflict of interest to
Lincoln Investment to use Pershing as a custodian and share classes offered by Pershing that provide
remuneration over other custodians and share classes that do not share these fees or payments, or that would
share lesser amounts, to offer the Sweep Products and to recommend that you utilize and maintain a greater
balance in the Sweep Products. Pershing offers other sweep products for which no remuneration or less
remuneration would be paid to Lincoln Investment, as introducing broker-dealer. The investment adviser to
Dreyfus Government Cash Management Fund Services Shares is BNYIA. BNYIA has engaged its affiliate,
Dreyfus, a division of Mellon Investments Corporation, to serve as the sub-investment adviser for Dreyfus
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Government Cash Management Fund Services Shares. Lincoln Investment has an incentive to offer/recommend
Dreyfus Government Cash Management Fund Services Shares due to its agreement with Pershing which
incentivizes us to offer Pershing or its affiliates’ products so that we may share in a portion of the revenue.
The Dreyfus Government Cash Management Fund Investor Shares Sweep Product, for which no distribution
assistance is received by Lincoln Investment, is available only to ERISA accounts and as the secondary Sweep
Product for balances in excess of $2,490,000 in the Level Fee Sweep Product.
As previously indicated, certain Program Banks as well as Sweep Products affiliated with Pershing are made
available within the Sweep Program. Due to Lincoln Investment’s custodial and clearing arrangement with
Pershing, this creates a conflict of interest for Lincoln Investment because it provides an incentive for us to offer
a Sweep Product and to recommend utilizing the Sweep Product so that Pershing receives additional
compensation and shares it with us.
For additional information and clarity regarding all Sweep Products offered including the designated Sweep
Product and secondary Sweep Product for your account, eligibility criteria, as well as applicable fees, rates, bank
lists, and conflicts of interest, please carefully review our Sweep Program disclosures, available on our public
website under our Disclosures section or at https://www.lincolninvestment.com/Disclosures. Please refer to The
Lincoln Investment Companies Sweep Program General Terms and Conditions to access the applicable money
market mutual fund prospectus.
In aggregate, the third-party payments and revenue sharing from Pershing to Lincoln Investment attributable to
Lincoln Investment advisory accounts in 2025 described above represented approximately seven percent of Lincoln
Investment’s total advisory revenue in 2025. The receipt of these third-party payments and expense credits create a
conflict of interest to Lincoln Investment to use Pershing as a custodian over other custodians that do not share these
fees, do not provide expense credits or that would share lesser amounts. Lincoln Investment mitigates these conflicts
by disclosing them to you and not sharing these payments/credits with your Advisor.
Other Conflicts and Potential Conflicts Related to Our Relationship to Pershing and its Affiliates
Trade Administration Fee Reduction. Lincoln Investment pays Pershing a fee based upon the amount of assets
in advisory programs for which Pershing provides trade administration services for Lincoln Investment advisory
accounts (“Trade Administration Fee”). Pursuant to written agreements with Pershing and BNYMA, Lincoln
Investment is eligible for an approximate 34% reduction in the Trade Administration Fee, contingent upon
attainment and maintenance of agreed upon asset levels invested in certain BNY affiliated products or services
by Lincoln Investment and its affiliate, Capital Analysts. Clients do not directly benefit from this expense
reduction. Lincoln Investment’s eligibility for this expense reduction creates a conflict of interest to Lincoln
Investment and its affiliate, Capital Analysts, to recommend and/or use Pershing as a custodian and/or trade
administrator and certain BNY affiliated products or services over other custodians, trade administrators or
products/services that do not provide for expense reductions or that would provide for lesser reductions to us.
BNY affiliated products include but are not limited to certain BNY affiliated mutual funds and ETFs.
Additionally, under our agreements with Pershing and BNYMA, Lincoln Investment and/or Capital Analysts
must continue to meet or surpass the agreed upon asset levels invested in certain BNY affiliated products or
services in order to continue to receive the reduction in Trade Administration Fee. Therefore, Lincoln Investment
and its affiliate, Capital Analysts, have an incentive to continue to meet or surpass the agreed upon asset levels
invested in certain BNY affiliated products or services.
BNYMA Overlay Fee Reduction. Lincoln Investment pays BNYMA a fee based upon the amount of assets in
advisory accounts where BNYMA acts as Overlay Manager (“Overlay Fee”). Pursuant to written agreements
with Pershing and BNYMA, Lincoln Investment is eligible for up to a 40% reduction in the Overlay Fee,
contingent upon attainment and maintenance of agreed upon asset levels invested in certain BNY affiliated
products or services by Lincoln Investment and its affiliate, Capital Analysts. Clients do not directly benefit from
this expense reduction. Lincoln Investment’s eligibility for these expense reductions creates a conflict of interest
to Lincoln Investment and its affiliate, Capital Analysts, to recommend and/or use Pershing as a custodian,
BNYMA as Overlay Manager and certain BNY affiliated products or services over other custodians, overlay
managers or products/services that do not provide for expense reductions or that would provide for lesser
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reductions to us. BNY affiliated products include but are not limited to certain BNY affiliated mutual funds and
ETFs. Additionally, under our agreements with Pershing and BNYMA, Lincoln Investment and/or Capital
Analysts must continue to meet or surpass the agreed upon asset levels invested in certain BNY affiliated
products or services in order to continue to receive this expense reduction. Therefore, Lincoln Investment and its
affiliate, Capital Analysts, have an incentive to continue to meet or surpass the agreed upon asset levels invested
in certain BNY affiliated products or services.
Mutual Fund Surcharge Fee Waiver. Lincoln Investment has agreed to pay Pershing a surcharge fee for
transactions in certain mutual fund share classes in Lincoln Investment advisory programs. Pursuant to written
agreements with Pershing and BNYMA, Lincoln Investment is eligible for a waiver of surcharge fees for
transactions in certain advisory programs traded by Pershing/BNYMA, continual application of which is
contingent upon attainment and maintenance of agreed upon asset levels invested in certain BNY affiliated
products or services by Lincoln Investment and its affiliate, Capital Analysts. Clients do not directly benefit from
this waiver. Lincoln Investment’s eligibility for this waiver creates a conflict of interest to Lincoln Investment
and its affiliate, Capital Analysts, to recommend and/or use Pershing as a custodian, BNYMA as Overlay
Manager and/or Pershing as trade administrator, and certain BNY affiliated products or services over other
custodians, overlay managers/trade administrators or products/services that do not provide for mutual fund
surcharge fee waivers or that would provide for lesser waivers. BNY affiliated products include but are not
limited to certain BNY affiliated mutual funds and ETFs. Additionally, under our agreements with Pershing and
BNYMA, Lincoln Investment and/or Capital Analysts must continue to meet or surpass the agreed upon asset
levels invested in certain BNY affiliated products or services in order to continue to receive these surcharge fee
waivers. Therefore, Lincoln Investment and its affiliate, Capital Analysts, have an incentive to continue to meet
or surpass the agreed upon asset levels invested in certain BNY affiliated products or services.
BNYMA Fund Selection in PPM Program. BNYMA has the authority to decide which mutual funds and ETFs
are made available within the Personal Portfolio Management (PPM) Program. In addition, BNYMA establishes
the default funds for Strategic Model Portfolios and Dynamic Model Portfolios in the PPM Program. BNYMA
can elect to utilize BNY affiliated funds for general availability in the PPM Program and as default funds for the
Strategic Model Portfolios and Dynamic Model Portfolios. For additional information regarding BNYMA’s
conflicts, see BNYMA’s Form ADV 2A and Appendix I. Lincoln Investment has a conflict in outsourcing fund
selection for the PPM Program and default fund selection for the Strategic Model Portfolios and Dynamic Model
Portfolios to BNYMA due to the inclusion of BNY affiliated funds selected by BNYMA, for which Lincoln
Investment receives certain fee and expense reductions or waivers contingent on meeting a certain threshold of
BNY affiliated products or services.
Pursuant to a written agreement, Lincoln Investment is obligated to provide certain providers/custodians, such as
Pershing and its affiliates, including BNYMA, the opportunity to participate in Lincoln Investment’s conferences or
events, without the separate payment of sponsor or registration fees. The ability to participate in such events
provides Pershing, BNYMA and its affiliates the opportunity to promote their affiliated products and services to
Lincoln Investment, its affiliate Capital Analysts and our Advisors. Increased use of BNY affiliated products and
services by Advisors of the firm will benefit the firm by assisting us with meeting the asset levels required for us to
receive a reduction/waiver in certain Pershing/BNYMA expenses. Platforms/custodians, including
Pershing/BNYMA, can waive or negotiate their respective fees assessed to you, Lincoln Investment, and/or your
Advisor, in each platform/custodian's sole discretion. Lincoln Investment is not required to pass the
waiver/reduction in cost along to you. We recognize these as conflicts for Lincoln Investment and its affiliate,
Capital Analysts, and mitigate these conflicts by disclosing them to you.
Sales & Marketing Support Revenue
Lincoln Investment receives Sales and Marketing Support as described below and includes Flat Fee Sponsors, Other
Sales Support and Asset and Sales Based Sponsors (collectively, “Sales and Marketing Support”). In order to
minimize the conflicts associated with the receipt of these fees, Lincoln Investment does not receive Flat Fee
Sponsor and Other Sales Support payments that are based on the amount of advisory account assets or advisory
account transactions with a particular sponsor, or that are based on ERISA advisory account assets. However, Flat
Fee and Other Sales Support Sponsors can compensate Lincoln Investment from assets of the mutual fund, the
fund’s investment adviser, distributor or other fund affiliate’s assets. While payments out of the fund's investment
adviser, distributor or other fund affiliate's revenues or profits are not directly paid from the fund's assets, fund
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affiliate revenues or profits can, in part, be derived from fees earned for services provided to and paid for by the
fund. Payments out of fund assets can lower investor returns and performance over time. Lincoln Investment can
also receive Shareholder Services Fees from the same fund families and investment advisers that provide Sales and
Marketing Support. These sources of payments are a conflict of interest to Lincoln Investment to recommend and
promote those funds, fund families, investment advisers, distributors or other fund affiliates over others that do not
provide Sales and Marketing Support or that provide lower amounts of Sales and Marketing Support.
Flat Fee Sponsors. Lincoln Investment has partnered with a select group of third-party money managers and
product sponsors who pay to assist Lincoln Investment in the training and education of and outreach to Lincoln
Investment’s Advisors, at Lincoln Investment sponsored events, on such topics as advisory products and
services, practice management, tools and technology, consumer education, and policies, rules and regulations.
Additional opportunities can include but are not limited to attendance at and support of recognition club events,
exhibit booths, advisor presentations, seminars, mailings and publications. These sponsors provide financial
support to Lincoln Investment in the form of a flat-dollar amount that may be amended annually and is not based
on the sales of their proprietary products or services. Sponsors can compensate us from fund assets, the fund’s
investment adviser, distributor or other affiliate’s assets. Payments made out of fund assets can lower investor
returns and performance over time. Advisors do not share in any portion of these payments so as to mitigate any
conflict for an Advisor to recommend one product or money manager over another. This financial support allows
Lincoln Investment to defray or offset costs associated with Lincoln Investment sponsored events and other
educational and outreach tools and services. The financial support by these Sponsors to Lincoln Investment
presents a conflict of interest.
All Flat Fee Sponsors do not pay Lincoln Investment the same amount, and depending on the amount of the
payment from the Flat Fee Sponsor, the access to Lincoln Investment sponsored events can differ. For example,
Lincoln Investment holds a number of sales conferences both nationally and regionally throughout the year to
educate advisors. The higher the annual flat fee payment, the more events the Flat Fee Sponsor will be invited to
attend. Flat Fee Sponsors have more opportunities than other product sponsors and money managers that are not
Flat Fee Sponsors to market to and educate Advisors, which could pose a conflict to Advisors to offer these
sponsors’ products or services over others. Advisors do not share in any portion of these payments so as to
mitigate any such conflict.
In 2025, the financial support from Flat Fee Sponsors paid to Lincoln Investment, as allocated across all
investment advisory assets with Lincoln Investment Planning, LLC and its affiliate, Capital Analysts, LLC did
not exceed one percent of total revenue for either of the affiliated registered investment advisers and in aggregate
was less than one percent of the combined revenue for both affiliated registered investment advisers. We do not
believe that these revenues are material. In 2025, Flat Fee Sponsors who compensated Lincoln Investment with a
flat fee payment, and offer a fund or advisory program that could be used in your advisory account, in order from
highest to lowest payment were Russell Investments, Clark Capital Management, AAMA, American Funds,
PIMCO Funds, Meeder Funds, Security Benefit Life, Nationwide, Transamerica Life, Federated Investors, BNY
Mellon, and Doubleline.
Some of the Flat Fee Sponsor revenue is used by Lincoln Investment to support the ongoing operational
expenses of Lincoln Investment, and its affiliates, and not used solely for sales and marketing support.
Other Sales Support. From time to time, product sponsors and third-party money managers assist Advisors in
their sales and marketing efforts by subsidizing certain Advisor costs, such as client meetings or workshops,
mailings, administrative expenses and technology support. The amount received from any one product sponsor
or third-party money manager in 2025 did not exceed $35,000. The sales support presents a conflict of interest in
that it could incentivize an Advisor to offer one product or money manager over another that does not provide
these subsidies or provides lesser amounts. To mitigate the conflict of interest presented by these payments and
subsidies, the amount is approved by Lincoln Investment and is monitored to ensure that it is not too frequent or
excessive. Also, Advisors are invited from time-to-time by product sponsors to due diligence and educational
meetings or seminars hosted by the product sponsor or money manager. This presents a conflict of interest that
could incentivize an Advisor to offer one product or money manager over another that does not offer these
meetings or seminars. Lincoln Investment must grant permission to our Advisors to attend any meeting or
seminar hosted by a product or advisory service sponsor. Lincoln Investment approves events that are limited to
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education or due diligence only and allows the product sponsor to provide meals, hotel accommodations and
reimbursement to the Advisor, through Lincoln Investment, for travel expenses only. The education of our
Advisors in the offerings that are available to them is a key component of providing prudent investment advice
to you.
Ancillary Sales & Marketing Support Revenue paid to Lincoln Investment that is not tied to your Advisory
assets, or the platform where your Advisory assets are held, but is tied to the Non-Advisory assets or
transactions in which you may invest
Asset and Sales Based Sponsors. In connection with non-investment advisory (non-fee-based) assets of our
investors, and in addition to the compensation described above, Lincoln Investment receives Sales and
Marketing support from product sponsors, mutual fund companies, insurance companies and other third-party
providers to assist in the marketing and sales efforts of employees and Advisors (“Asset and Sales Based
Sponsors”). Asset and Sales Based Sponsors have the opportunity to educate and train employees and Advisors
with respect to investment products and services, practice management, tools and technology, consumer
education, and policies, rules and regulations. Additional opportunities can include but are not limited to
attendance at and support of recognition club events, exhibit booths, advisor presentations, seminars, mailings
and publications. The support provided by these sponsors is based on brokerage-only (non-investment advisory)
assets and brokerage transactions and not based on your advisory account assets or ERISA advisory assets. We
receive compensation from these sponsors in various forms, including as a flat fee, a percentage of the amount of
brokerage assets held by investors, a percentage of sales, or any combination of these methods. The amounts of
these payments can vary by the type of product and by provider and can include, but are not limited to,
distribution fees and shareholder service fees. All Asset and Sales Based Sponsors do not pay Lincoln
Investment the same amount, and depending on the amount of the payment, the access to Lincoln Investment
sponsored events and other opportunities can differ. The higher the payment, the greater the access for the Asset
and Sales Based Sponsor to attend events, participate in marketing and sales opportunities and interact with
Advisors. This presents a conflict of interest to Advisors to offer these sponsors’ products or services over
others. Advisors do not share in any portion of these payments so as to mitigate any such conflict. Additionally,
some Asset and Sales Based Sponsors make a monthly or quarterly payment or additional monthly or quarterly
payment based on the assets you hold in a fund or variable insurance product over a period of time. As you may
have both a brokerage account and an advisory account with us, we want you to understand that Lincoln
Investment will receive Sales and Marketing Support based on assets or sales in connection with your brokerage
account assets and transactions. The Asset and Sales Based Sponsors payments present a conflict of interest to
Lincoln Investment to recommend Asset and Sales Based Sponsors that provide sales and marketing support
over others that do not or that provide lesser amounts. Some of the Asset and Sales Based Sponsor revenue is
used by Lincoln Investment to support the ongoing operational expenses of Lincoln Investment, and its affiliates,
and not used solely for sales and marketing support.
The following is a list of Asset and Sales Based Sponsors in order of high to low total compensation paid to
Lincoln Investment as broker-dealer based on non-fee based account assets or sales in 2025: Security Benefit
Life, Franklin Templeton Group, Jackson National Life Ins Co, Allianz, Lincoln National Life, Athene,
Nationwide, AXA Equitable Life Insurance Company, Prudential, Brighthouse Financial, Pacific Life,
Transamerica Life, Mewbourne Development Corporation, Simplicity, the Standard, Pershing, Blue Rock
Capital, Voya Mutual Funds, and Meeder Funds. The Asset and Sales based Compensation in 2025 was less than
$3 million dollars from these product sponsors and represented less than one percent of the total revenues of
Lincoln Investment. We are disclosing this information to you as certain providers and products offered by the
providers shown above could be available within our investment advisory offerings.
Outside of the Sweep Program, Pershing, as clearing firm for accounts introduced by Lincoln Investment, shares
with Lincoln Investment a nominal amount of asset-based revenue it receives from certain mutual fund
companies in non-advisory accounts. As this revenue received from Pershing is non-advisory related and not
material, Lincoln Investment is disclosing the conflict that we receive this revenue rather than list each mutual
fund product that generated the compensation to the firm.
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Other Conflicts and Potential Conflicts
Other financial services firms and third parties could offer advisory services, securities products, or insurance at a
lower overall cost to you than what is available through your Lincoln Investment account, or you could invest
directly with a provider.
Ongoing Fiduciary Conflicts. Lincoln Investment has a supervisory duty to periodically monitor clients’
portfolios to ensure suitability of investments and to ensure that the advisory services are being performed in
recognition of our fiduciary duty to you, which includes acting in your best interest. A conflict of interest exists
if an Advisor is assessing an advisory fee, but no services are being performed. Supervision is performed over
accounts and Advisors to monitor for activities that could be deemed a breach of our fiduciary duty to you,
including such periodic reviews as accounts where there is no documentation of services being performed and
accounts with uninvested cash balances over a 12-month period of time with no rationale for holding such a
large cash position in an advisory account. In an advisory relationship, our fiduciary relationship will be most
successful if both the client and the Advisor partner to ensure that there is regular and meaningful contact and
that the advisory account continues to meet the needs of the client.
Lincoln Investment’s Other Businesses. Lincoln Investment’s principal business is as an investment adviser.
The majority of Lincoln Investment’s revenue comes from the advisory fees we collect from you. As a broker-
dealer, Lincoln Investment also receives compensation from its brokerage business. This compensation comes
from securities and insurance product commissions and mutual fund concessions, 12b-1 distribution fees
associated with the sale of mutual funds, shareholder service fees, reallowances, trailing commissions from
annuity sales, and persistency bonuses on insurance and other sources. Lincoln Investment, acting as both a
broker-dealer and registered investment adviser, could be deemed a conflict of interest. This places an additional
responsibility on Lincoln Investment to supervise whether a recommendation to open either an advisory account
or a commissionable account, or both, is appropriate. You always have the option to purchase advisory services,
securities products or insurance through non-affiliated investment advisers, brokers or agents. Lincoln
Investment also is affiliated with registered investment adviser, Capital Analysts, LLC, and promotes the
services of this investment adviser.
Your Advisor’s Other Businesses. Your Advisor can have more than one relationship with you. Your Advisor
acts as an investment adviser representative when he or she provides advisory services to your account and earns
advisory fees based on your assets under management/advisement, and/or when he or she provides planning
services to you and earns a flat or hourly fee. Your Advisor acts as a registered representative/agent when he or
she makes recommendations to you for your non-advisory account where he or she receives a sales commission
for the sale of securities or insurance products, which would be in addition to any advisory fees earned in your
advisory account. In these situations, your Advisor may have greater financial incentives to offer you both
investment and/or insurance sales as well as advisory services. In addition, if a planning services client chooses
to implement any planning recommendations, your Advisor may have greater financial incentives to offer you
both investment and/or insurance sales as well as advisory services.
Your Advisor can also be associated with Lincoln Investment’s affiliated investment adviser, Capital Analysts,
LLC. These affiliated relationships present a conflict of interest. Through his or her affiliation with Lincoln
Investment and possibly with Capital Analysts, your Advisor is in a position where he or she can offer the same
or similar advisory services to you for different fees and compensation structures. If an identical Sub-Adviser,
third-party manager or strategy is available through two affiliated registered investment advisers, you could pay
higher fees for an advisory service that is similarly offered through another affiliated investment adviser. You
always have the option to purchase advisory services, securities products or insurance through non-affiliated
investment advisers, brokers or agents.
Lincoln Investment pays out to each Advisor a specified percentage of the Advisor’s fee. This percentage varies
by Advisor based on such factors as Advisor experience, type of contract the Advisor has with the firm, amount
of investor assets with the firm, type of advisory service, categories of products and the amount of investor assets
managed by the IM&R Team. These varying payout rates create a conflict of interest for your Advisor to
recommend certain services and categories of products, including advisory services managed by the IM&R
Team and your Advisor, over others with a lower payout rate. Lincoln Investment can pay compensation,
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including bonus payments, to Advisors who agree to engage in mentorship of another financial professional.
Most of Lincoln Investment’s Advisors are independent contractors who may also offer other non-security
financial services and products, such as life, health, disability, long-term care and fixed annuity insurance
products, and real estate. These services may be offered independent of The Lincoln Investment Companies.
Security recommendations may be limited to products offered by the broker-dealer. Although a client always has
the ability to purchase security products through other broker-dealers, the fee schedule for services described
herein may have been structured with the understanding that clients will implement financial product
recommendations through the Advisor. You are under no obligation to implement, in whole or in part, any
recommendation, advice or suggestion made by your Advisor. You may take any such recommendation, advice
or suggestion available from any other professional retained by you to assist in the implementation of the
planning services. If you choose to implement your Advisor’s recommendations and open an investment
advisory account or add an additional service through Lincoln Investment and/or Capital Analysts, then, prior to
making the decision to implement, you should read Lincoln Investment’s and/or Capital Analysts’ Investment
Advisory Disclosure Brochure and Wrap Fee Brochure for a description of conflicts and potential conflicts of
interest that we have identified in the conduct of our business that we believe may be material to any
recommendations when implemented through us.
Sales Contests. Lincoln Investment offers sales contests based on such criteria as gross compensation to the
Advisor, new accounts, new investors, initiation of periodic contributions, total fee-based assets and net sales of
fee-based programs. These contests can provide your Advisor with a conflict of interest and an incentive to offer
you fee-based advisory services over commission-based brokerage services, offer you advisory services
managed by the IM&R Team and your Advisor over third-party advisory services and to conduct additional
business in order to be eligible. Top achievers in these contests are eligible to receive Lincoln Investment-
sponsored trips, awards, cash prizes, bonus commissions, bonus payments, club points, monetary donations in
their name to a charity of their choice or other nominal prizes subject to applicable law. To mitigate the conflicts
of interest presented by these incentives, no contest is offered which will award the Advisor based upon a
specific investment product or on a specific third-party product sponsor. Brokerage commissions and brokerage
assets associated with Massachusetts residents are excluded from Lincoln Investment’s sales contests consistent
with applicable state law. For Massachusetts’ residents, this creates a financial incentive for your Advisor to
recommend advisory services over brokerage services. Lincoln Investment mitigates these conflicts by
disclosing them to you and supervising the investment advisory activities and brokerage practices of its
Advisors. In our capacity as an investment adviser, Lincoln Investment and its Advisors recognize they have a
fiduciary duty to investment advisory clients. Although Lincoln Investment does not offer specific product sales
incentives for securities products, issuers of non-securities insurance products, such as fixed annuity issuers, may
offer sales incentives to Advisors in the form of cash bonuses and trips if certain sales thresholds are met. You
should ask your Advisor about these incentives at the time of sale.
Payments to Employers and Organizations Associated with an Employer who Sponsor Non-ERISA Plans.
Lincoln Investment has contracts with employers to enable employees who work for these employers to open
and invest in a primary or supplemental retirement account through payroll deduction contributions through an
account with us. The majority of employers with whom Lincoln Investment has contracts offer non-ERISA
403(b) and 457(b) retirement plans to their employees. Also, many of these employers are school districts and
the employees are teachers or other eligible employees. Lincoln Investment and our Advisors make contributions
from time-to-time to organizations that are associated with an employer, such as administrators and teachers’
associations, consultants, non-profits, and scholarship or grant funds. Lincoln Investment and our Advisors can
also sponsor a business or social event, conference, meeting, fundraiser or scholarship by making a monetary
contribution or by providing nominal supplies to assist the employer and/or their employees.
Third Party Administrator (TPA) Payments. TPAs that provide administrative services to the employer charge
the employer an annual per participant retirement plan administration fee for their services. Certain TPAs and/or
employers list Lincoln Investment as an investment provider (along with other providers) and we have agreed to
pay the per-participant TPA fee for a participant who opens or holds an account with us. This reduces the cost to
the employer sponsor of the retirement plan and/or the participant.
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Exclusive Provider. Less than one percent of our employer contracts are an exclusive arrangement where
Lincoln Investment is the only provider who has been authorized to work with the employees to establish a
primary/supplemental retirement plan account. You can ask your Advisor whether Lincoln Investment has an
exclusive arrangement with your employer.
Other Non-Exclusive Provider Payments. In order to be a 403(b) provider/vendor in California,
providers/vendors must register with 403bCompare, a program of the California State Teachers’ Retirement
System (“CalSTRS”). Lincoln Investment is registered with 403bCompare and pays an annual 403(b)
provider/vendor fee as determined and assessed by CalSTRS. The total fee assessed to all providers/vendors
covers the cost to administer and maintain the 403bCompare.com website.
The payments and benefits described in this section create a conflict of interest to the employer and employees
since they could serve as an incentive to select the products and services of Lincoln Investment and its affiliates
over other providers that do not make these payments or pay lesser amounts. We mitigate these conflicts by
disclosing them to you and avoiding payments that we consider too frequent or excessive.
Loans, Advances and Other Benefits. Lincoln Investment can extend loans, provide bonuses and other
benefits, provide commission/fee advances, and pay for practice management services for an Advisor to assist
the Advisor in transitioning to the firm, and/or maintaining or expanding his or her business. Lincoln Investment
does not verify that any payments made are used for these purposes. Sometimes the availability and amount of
loans and advances are conditioned upon, are forgiven (waived) or reduced, in whole or in part, interest rates
reduced, and/or bonuses provided if an Advisor remains affiliated with the firm or achieves certain sales or
assets under management thresholds, revenue targets, production levels, asset additions, new client goals, client
retention goals, recruiting goals and certain practice management goals or conditions, individually or with other
Advisors. These practices present a conflict of interest in that the Advisor has a financial incentive to affiliate
with and remain affiliated with the firm during the repayment period in order to receive these benefits over other
firms that do not offer these incentives or offer a similar level of incentives. These practices also present a
conflict in that the Advisor has a financial incentive to generate more business or to recruit other financial
professionals to generate more business, and achieve certain sales, revenue, asset additions or asset management
thresholds in order to receive a loan or advance, increase the amount of the loan or advance, and/or satisfy or
reduce the amount of the loans or advances. The extent of the conflict can increase as your Advisor approaches
certain milestones. In situations where a sales, production, recruiting, revenue, asset additions, assets under
management threshold or other financial contingency exists, this conflict of interest will be disclosed in your
Advisor’s Form ADV 2B Supplement (“BIO Brochure”), which is required to be delivered by the Advisor to
every client. Lincoln Investment mitigates these conflicts by disclosing them to you and supervising the
investment advisory activities and brokerage practices of its Advisors.
Additionally, Lincoln Investment can extend a loan or advance to an Advisor for which repayment is required
which can create a conflict for the Advisor to generate more business in order to repay the loans or advances to
the firm during the repayment period. Additionally, some Advisors receive benefits as they transition to the firm
and/or for maintaining their business, which can include but is not limited to, technology services, administrative
support, licensing, insurance and administrative fees, the opportunity to participate in a unit appreciation rights
plan of an affiliate or parent of Lincoln Investment, and reimbursement of fees associated with transitioning
accounts. These practices present a conflict of interest in that the Advisor has a financial incentive to affiliate
with and remain affiliated with the firm over other firms that do not offer these incentives or offer a similar level
of incentives. Lincoln Investment mitigates these conflicts by disclosing them to you and supervising the
investment advisory activities and brokerage practices of its Advisors.
Advisor Referral Program. Lincoln Investment compensates Advisors and employees who have referred
another financial professional to the firm if that referred financial professional then decides to affiliate with
Lincoln Investment or an affiliate. This creates an incentive for Advisors and employees to affiliate with our firm
over others that do not offer similar compensation, and to refer financial professionals in order to receive this
compensation. We do not believe that this practice presents a material conflict of interest.
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Gifts and Entertainment. Offering or receiving a gift or entertainment from a product or advisory service
sponsor could create a conflict of interest. Lincoln Investment has instituted a policy that prohibits excessive
and/or too frequent gifts or entertainment activities to mitigate this conflict.
Political Contributions. Providing significant political contributions to a state or local official or candidate
could create the perception that Lincoln Investment or its Advisors are seeking quid pro quo arrangements with
that state or local government or its employees to open an account with our firm. Lincoln Investment prohibits
contributions in excess of $350 per election if the Advisor can vote for the candidate and $150 per election if the
Advisor cannot vote for the candidate.
Charitable Donations. Providing significant charitable donations to a charity organization could create the
perception that Lincoln Investment or its Advisors are seeking quid pro quo arrangements with that charity or its
employees to open an account with our firm. Lincoln Investment allows contributions to charities but prohibits
any donations that are deemed excessive or too frequent.
Accounts Maintained on Institutional Platforms
The following applies to clients whose accounts are held at Schwab and Fidelity (“Institutional Platforms”).
Lincoln Investment’s Advisors can recommend that clients establish brokerage accounts with one or more
Institutional Platforms to maintain custody of clients’ assets and to effect trades for their accounts. The final
decision to custody assets with an Institutional Platform is at the discretion of the Advisor’s clients, including
those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan
sponsor or IRA accountholder.
Products & Services Available to Us from Institutional Platforms
Institutional Platforms serve independent investment advisory firms like ours. They provide Lincoln Investment
and our clients with access to its institutional brokerage – trading, custody, reporting and related services – many
of which are not typically available to the Institutional Platform’s retail customers. Institutional Platforms also
make available various support services. Some of those services help us manage or administer our clients’
accounts while others help us manage and grow our business. Institutional Platform support services are
generally available on an unsolicited basis and at no charge to us. Some institutions such as Charles Schwab and
Co., Inc. require we maintain a total of at least $10 million of our clients’ assets in accounts at Schwab to avail
ourselves of those services at no charge. These Institutional Platform providers generally do not charge
separately for custody services but are compensated by account holders through commissions or other
transaction-related or asset-based fees for securities trades that are executed through them or that settle into their
accounts.
Services that Benefit Clients
Institutional brokerage services include access to a broad range of investment products, execution of securities
transactions, and custody of client assets. The investment products available through Institutional Platforms
include some to which we might not otherwise have access or that would require a significantly higher minimum
initial investment by our clients. These services generally benefit clients or their account(s).
Services that May Not Directly Benefit Clients
Institutional Platforms also make available to us other products and services that benefit us but may not directly
benefit the client or their account(s). These products and services assist us in managing and administering our
clients’ accounts. They can include both their own investment research and that of third parties. We can use this
research to service all or some substantial number of our clients’ accounts, including accounts not maintained at
the Institutional Platform providing the services. In addition to investment research, Institutional Platforms make
available software and other technology that:
•
•
provides access to client account data (such as duplicate trade confirmations and account statements);
facilitates trade execution and allocate aggregated trade orders for multiple client accounts;
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•
•
•
provides pricing and other market data;
facilitates payment of our fees from our clients’ accounts; and
assists with back-office functions, recordkeeping and client reporting.
Institutional Platforms also offer other services intended to help us manage and further develop our business
enterprise. These services can include:
•
•
•
•
educational conferences and events;
technology, compliance, legal, and business consulting;
publications and conferences on practice management and business succession; and
access to employee benefits providers, human capital consultants and insurance providers.
Institutional Platforms may provide some of these services. In other cases, they will arrange for third-party
vendors to provide the services. They can also discount or waive their fees for some of these services or pay all
or a part of a third party’s fees. While, as a fiduciary, Lincoln Investment endeavors to act in its clients’ best
interests, Lincoln Investment’s recommendation that clients maintain their assets in accounts at the Institutional
Platform can be based in part on the benefit to Lincoln Investment or its Advisors of the availability of some of
the foregoing products and services and other arrangements and not solely on the nature, cost or quality of
custody and brokerage services provided by these Institutional Platforms, which creates a conflict of interest.
Item 5: Account Requirements and Types of Clients
Types of Clients
Lincoln Investment primarily serves individuals, high net worth individuals, trusts, businesses, and charitable
organizations as well as the retirement assets of individuals and businesses, including, through IRC 403(b) and 457
programs, individual retirement accounts (“IRAs”) and employer sponsored ERISA plans. We also offer our
institutional investment advisory services to third-party investment advisers and trust companies. Clients may open
qualified and non-qualified accounts with Lincoln Investment. Not all investors and plans, including retirement
plans, are eligible to invest in one or more of Lincoln Investment's advisory programs. Please consult with your
Advisor or your employer to determine if your assets are eligible to invest. Please consult with your Advisor for
more information on minimum account size requirements.
Account Requirements
A minimum account size exists for the Wrap Fee Programs offered by Lincoln Investment. Lincoln Investment or
the Third-Party Managers may, from time to time, amend or waive the minimum account size. Consult with your
Advisor for more information on minimum account size requirements. For Wrap Fee Program minimums, see the
Description of Wrap Fee Programs and Fees earlier in this brochure.
Item 6: Portfolio Manager Selection and Evaluation
This section discusses how Lincoln Investment selects and evaluates Wrap Fee Programs and portfolio managers,
and any conflicts of interest related to its selections, other than as described in Item 4; if performance-based fees
are assessed in any Wrap Fee Program; the methods of analysis, investment strategies and the risk of loss
associated with the Wrap Fee Programs offered; and Lincoln Investment's Proxy Voting policy.
Lincoln Investment’s IM&R Team routinely reviews the advisory services managed, sponsored, and/or offered by
Lincoln Investment, including the Wrap Fee Programs, portfolio managers, and Sub-Advisers. A description of the
IM&R Team is provided in the supplement at the end of this brochure. The IM&R Team performs the following
roles on Lincoln Investment’s behalf:
• The management of all Lincoln Investment managed model portfolios
• The selection of advisory services offered by Lincoln Investment
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• The monitoring of advisory services offered by Lincoln Investment
• The removal of advisory services offered by Lincoln Investment
In determining which Wrap Fee Programs, portfolio managers, or Sub-Advisers are selected, the IM&R Team
utilizes a preliminary screening process involving a variety of criteria, such as assets under management, personnel,
registration, disclosures and regulatory history, together with other quantitative and qualitative criteria. Lincoln
Investment does not independently verify the accuracy of performance information provided to Lincoln Investment
by another investment adviser.
The ongoing due diligence and monitoring process may result in the replacement of or recommendation for
replacement of a portfolio manager or Sub-Adviser by the IM&R Team.
Advisory Services Offered by Lincoln Investment Other than Wrap Fee Programs
Lincoln Investment offers advisory services that are not Wrap Fee Programs. For further information regarding
these advisory services, please see Lincoln Investment's Investment Advisory Brochure (Form ADV Part 2A)
attached.
Performance-Based Fees and Side-by-Side Management
Lincoln Investment and our Advisors do not receive performance-based fees. A performance-based fee is an
advisory fee that compensates the advisor for the advisor's success in managing his or her client's money or "a fee
based on the share of the capital gains and appreciation of a client's funds." A performance-based fee may induce an
advisor to take greater and undue risks with client's funds in an attempt to generate higher compensation to the
advisor.
Your Wrap Fees with Lincoln Investment are assessed as a percentage of the total value of your advisory account
assets as of each month-end and are not performance-based fees.
Methods of Analysis, Investment Strategies and Risk of Loss
Investing in securities involves risk of loss that you, the investor, should be prepared to bear.
The advisory services and advice offered by Lincoln Investment and its Advisors primarily attempt to provide to you
risk-appropriate diversified portfolios comprised of primarily mutual funds. A risk-appropriate diversified portfolio
applies the disciplines and theories of asset allocation. Asset allocation means, first and foremost, working to design
a portfolio that sufficiently allocates your assets across different asset classes to help reduce the exposure to any
single asset class and market loss you could incur in your account(s) if you didn’t diversify. It is important to
understand that asset allocation, although a proven theory to reduce risk to a portfolio, does not guarantee a profit or
protect against loss. A diversified portfolio typically will not perform as well as a stock market index, such as the
S&P 500, in a rising market environment, and it will typically not decline as much in a declining market
environment.
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 commodities. Equities can
be further broken down by market capitalization (company size based on annual revenues) ranging from large
companies (large-cap) to medium and small companies (medium- 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.
Your Advisor will determine with you your risk profile and objectives, create an asset allocation policy, recommend
a risk appropriate well diversified portfolio, and may periodically re-balance the account (as directed) back to any
stated asset allocation, if any. Your Advisor will also periodically review your account with you to determine if any
additional changes should be recommended or made to your account. Your Advisor can analyze your financial
situation provided you make available to them your personal and financial data, employee benefit and retirement
programs, business continuation plans and even your most recent estate planning arrangements. The Advisor can
coordinate with your attorney, accountant, and other staff to discuss solutions. If your Advisor analyzes your
investment portfolio, the security analysis methods may include charting, fundamental, technical or cyclical
analysis.
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Lincoln Investment primarily uses mutual funds and ETFs, but can also use equity securities, fixed income
securities, ETNs, options or cash depending upon the advisory wrap fee 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. Each mutual fund will then be assigned by Lincoln Investment into one of the asset classes identified above
and the mutual funds that best meets Lincoln Investment's proprietary criteria for inclusion in a Wrap Fee Program
will be selected. 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,
described in more detail below.
Using a risk appropriate diversified portfolio, Lincoln Investment uses two approaches to further manage your
money in its Asset Management Program advisory services: a Strategic approach and a Dynamic (or 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 within the designated risk tolerance. There is
typically no change in the asset classes within these model portfolios. Each portfolio manager can select
and replace different securities within those asset classes.
• Dynamic (also referred to as Tactical): A strategy that makes market trades in your portfolio in an
attempt to take advantage of potential market opportunities within the designated risk tolerance. There can
be changes in the asset classes and industry sectors within these model portfolios. Each portfolio manager
can vary the asset allocations within each model portfolio in an attempt to capture market opportunity.
In the Strategic Asset Management Programs managed in-house by the IM&R Team, the selection of mutual funds
for the asset management programs uses a quantitative approach that takes into consideration such factors as: current
style of the fund, style consistency, R-squared, as well as multiple performance factors and the expense ratio of the
fund. This quantitative approach is utilized to assist with management of model portfolios, including, but not limited
to, the following asset management programs: Dividend Income, Lincoln Strategic, Progressive Asset Management
and Progressive Asset Management ESG.
In the Dynamic asset management programs managed in-house by the IM&R Team, the team uses a mixture of tools
in the management of our discretionary Adaptive Intelligence Model (“AIM”) Asset Management Programs. Our
investment discipline incorporates research, quantitative and qualitative tools, and neural networks into portfolio
management decisions in an effort to highlight asset class absolute and/or relative strengths which can be
incorporated into portfolio management decisions. Any neural network tool associated with AIM is just one tool and
does not in and of itself make any investment decisions. A neural network is a computer system that uses
mathematical algorithms to simulate certain cognitive processes of a biological neural network, such as the human
brain. Neural networks sift through data, using user-defined parameters, to identify patterns which generate
directional information across multiple asset classes, and determine relative strengths of those asset classes. The
aforementioned tools or data outputs generated from these tools can be used individually, in concert with one or
multiple other tools, or not used at all, at the discretion of the Lincoln Investment Portfolio Manager, to assist with
management of model portfolios in the AIM programs.
For our risk-adjusted AIM model portfolios (such as Conservative Income, Conservative Growth & Income,
Balanced, Total Return, Appreciation, and Growth Portfolios), we may utilize one or more of the research materials
and quantitative and qualitative tools to make specific percentage allocation recommendations by asset class for
each risk level model portfolio. These recommendations take into consideration the investment objective(s) and risk
tolerance of an AIM model portfolio when providing such asset class weightings. Lincoln Investment does not
employ risk tolerance constraints for all AIM advisory model portfolios in the same manner. The AIM Absolute
Return and Managed Income & Growth model portfolios generally do not have as stringent risk tolerance
constraints (i.e., there is little to no limitation as to the exposure your account will have to any given asset class).
In their investment decision-making process, the Lincoln Investment Portfolio Manager may use the aforementioned
tools, along with fundamental and technical analysis, to develop asset allocation recommendations for our dynamic
asset allocation model portfolios. Once asset allocation recommendations are developed, we utilize our Fund
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Selector screening program to make quantitatively supported projections as to the mutual funds, exchange-traded
funds (“ETFs”), and variable annuity sub-accounts for insight on future market performance within each asset class.
The Fund Selector program uses variations of mathematical equations and proprietary formulas that assess the rate
of consistency for fund performance and risk measurements. Subjective qualitative methodologies may also be used
to identify and compensate for anomalies in the quantitative research. For example, if a fund has experienced a
managerial change in the past year, the Portfolio Manager may combine performance from the manager’s previous
fund to gain a broader perspective of their management skills.
There is no guarantee that the investment recommendations made by Lincoln Investment’s Portfolio Manager with
the assistance of research materials, quantitative and/or qualitative tools, or any of our other models in the future
will be accurate. These tools and others can be used or considered at the discretion of the Lincoln Investment
Portfolio Manager and they do not in and of themselves make any investment recommendations or decisions with
regard to management of the AIM model portfolios.
The management of all CAAMS IM&R managed programs includes investment selection and monitoring, portfolio
construction, and portfolio rebalancing and realignment in accordance with the investment objectives of the
managed model portfolio.
Investment strategies include both long-term solutions and short-term strategies, where appropriate, that coordinate
with either the client’s stated objectives (when managing a custom portfolio) or the objectives of the model portfolio
(when managing the model to a stated objective). Our goal is to manage the portfolio with the appropriate asset mix
to optimize portfolio return within the given level of risk tolerance. Option writing may be used from time to time.
The investment management strategies of the CAAMS IM&R managed programs differ by Program and by model
or custom portfolio, and can be strategic or involve dynamic overlays. Investing in securities involves risk of loss
that you, the investor, should be prepared to bear.
For CAAMS IM&R managed programs, the IM&R Team utilizes a proprietary screening and rating methodology
for mutual funds called CAPSL. The IM&R Team also offers Advisors the results of CAPSL for consideration with
Advisor Managed Model and/or Client Custom Portfolios. The objective of CAPSL is to identify mutual funds that
consistently outperform their peers and the market for consideration of inclusion in diversified investment portfolios.
While the CAPSL list represents funds that have exhibited strong characteristics over full market cycles, it is by no
means a buy list. CAPSL is a comprehensive mutual fund research tool proprietary to Lincoln Investment. On a
quarterly basis, the IM&R Team screens U.S. open-ended funds for inclusion on the CAPSL list. Morningstar Direct
is used to quantitatively screen over 25,000 funds. Initial screens typically include funds with a five-year track
record and those that have at least $100 million in AUM. Qualifying mutual funds are sorted by Morningstar
category and undergo a multi-factor quantitative analysis. Finalists are further subjected to style analysis and a
qualitative analysis. The final CAPSL list of 125 funds represents less than 1% of the mutual fund universe. This
CAPSL list is made available to Advisors quarterly. However, the mutual fund recommendations of Advisors are
not limited to those on the CAPSL list.
For CAAMS IM&R managed programs which invest in stocks, the IM&R Team utilizes a proprietary research and
selection methodology which applies various fundamental and technical screens to the investable universe of stocks
and compares the results with current research recommendations of independent third-party research providers.
Additional investment research may also be factored into the stock selection process.
Lincoln Investment uses asset allocation and diversification in an attempt to achieve the objectives of our model
portfolios. Asset allocation involves allocating an investment portfolio among different asset classes, such as stocks,
bonds and cash. Our dynamic model portfolios are proactively reallocated to reflect changes in market expectations.
Diversification is the practice of spreading money among different investments to reduce risk.
For assets in programs managed by Lincoln Investment, Lincoln Investment may invest your assets in any asset
class we deem necessary in an effort to achieve a model portfolio’s objective. Such asset classes may include, but
are not limited to: large-capitalization domestic equities, mid-capitalization domestic equities, small-capitalization
domestic equities, high quality domestic debt, high yield domestic debt, international equities, emerging markets
equities, foreign debt, real estate investment trusts, real assets, Treasury Inflation-Protected Securities, agency
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securities and Commercial Mortgage-Backed Securities and cash.
In the Personal Portfolio Management (“PPM”) Program, Lincoln Investment works with BNYMA to select mutual
funds and ETFs available to your Advisor for selection within the PPM Program. Although Lincoln Investment
screens funds that it requests be made available in the program, ultimately, BNYMA decides whether to include or
exclude a fund from availability within the PPM Program. For Strategic Model Portfolios and Dynamic Model
Portfolios, Lincoln Investment applies strategic and dynamic asset allocation principles, respectively, in determining
asset class target allocations applicable to the model portfolios, and your Advisor selects from the available funds to
comprise each asset class target allocation percentage. For Custom Model Portfolios, your Advisor is permitted to
apply their chosen asset allocation methodology within the limits established by Lincoln Investment, and to select
from available funds to comprise each asset class target allocation percentage. BNYMA selects default funds for
Strategic Model Portfolios and Dynamic Model Portfolios. Should your Advisor select a Strategic Model Portfolio
or Dynamic Model Portfolio comprised of BNYMA-selected default funds, BNYMA will apply its own investment
selection methodology when choosing, removing, adding and changing fund allocations.
Investing in securities involves risk of loss that clients should be prepared to bear. Lincoln Investment cannot assure
that any portfolio will increase or preserve capital or generate income, nor can we assure that the objectives of any
model portfolio will be realized. Asset allocation decisions made by Lincoln Investment may result in a profit or
loss.
As more investments are added to a portfolio, fees and expenses may increase, which will, in turn, lower investment
returns. Diversification does not assure a profit or protect against a loss. Funds purchased for your account may
invest in different types of securities, such as value or growth stocks, real estate investment trusts, corporate bonds
or U.S. government bonds. There are risks associated with each asset class.
Because each fund within a portfolio owns different types of investments, portfolio performance will be affected by
a variety of factors. The value of your account will vary from day to day as the values of the underlying investments
you hold vary. Such variations generally reflect changes in interest rates, market conditions and other company and
economic news. These risks may become magnified depending on how much a fund invests or uses certain
strategies.
In overseeing the Select Manager Program, the IM&R Team utilizes a database that evaluates independent third-
party portfolio managers and strategies. Comparisons to both peers and appropriate benchmarks are evaluated. Each
third-party portfolio manager in the Select Manager Program develops their own proprietary research methodology,
investment analysis and risk strategies. Third-party portfolio managers are solely responsible for their investment
advice and services.
The asset classes and types of investments used by Lincoln Investment and your Advisor in implementing the
methods of analysis and investment strategies described above carry material risks.
• Cash & Cash Equivalents: Lincoln Investment may invest a portion of your assets in cash or cash
equivalents to achieve a model portfolio’s objective, provide ongoing distributions and/or take a defensive
position. Cash holdings may result in a loss of market exposure. For discretionary advisory programs managed
by Lincoln Investment, Lincoln Investment allocates a portion of account assets to the Sweep Product or free
credit balance. See Other Compensation to Lincoln Investment and Our Conflicts of Interest for additional
information and conflicts applicable to The Lincoln Investment Companies Sweep Program.
• Environmental, Social and Governance (ESG) Funds: Environmental, Social and Governance (“ESG”)
investing can be referred to in many different ways, such as sustainable investing, socially responsible
investing, and impact investing. ESG fund practices can include, but are not limited to, strategies that select
companies based on their stated commitment to one or more ESG factors (e.g., environmental, social and
governance) - for example, companies with policies aimed at minimizing their negative impact on the
environment or companies that focus on governance principles and transparency. Funds that elect to focus on
companies’ ESG practices may have broad discretion in how they apply ESG factors to their investment or
governance processes. An ESG fund portfolio might include securities selected in each of the three categories,
or in just one or two of the categories. A fund’s portfolio might also include securities that don’t fit any of the
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ESG categories, particularly if it is a fund that considers other investment methodologies consistent with the
fund’s investment objectives.
In selecting funds for Lincoln Investment’s ESG model portfolios, Lincoln Investment can consider data from
third-party providers. This data could include “scoring” and “rating” data compiled to help managers, such as
Lincoln Investment, compare funds. Some of the data used to compile third-party ESG scores and ratings may
be subjective. Other data may be objective in principle, but are not verified or reliable. Lincoln Investment’s
Portfolio Manager will make the ultimate decision as to whether or not a fund is ESG for purposes of the ESG
model portfolios and whether or not a fund should be included in the ESG model portfolios. Lincoln
Investment’s ESG model portfolios can include funds that take a diversified ESG approach (e.g., funds that fit
two or three ESG categories) or funds that target a specific ESG category (e.g., funds that fit just one ESG
category). Our ESG model portfolios can also include mutual funds that do not have any ESG mandate.
Lincoln Investment’s ESG practices may significantly influence performance. Because funds may be included
or excluded based on ESG factors rather than other investment methodologies, Lincoln Investment’s ESG
model portfolio performance may differ (either higher or lower) from the overall market or comparable model
portfolios that do not employ similar ESG practices.
• Equities: The price of equities fluctuate due to many factors including changes in interest rates, global events,
industry and company specific events, investor expectations, and general market conditions. You can receive
more or less than the original purchase price when selling a security. Concentrated positions in equities
typically pose additional risks as a downturn in your investment will cause a more significant loss.
Diversification assists in reducing concentration risk.
Equity mutual funds may include small-, mid- and large-capitalization stocks. Small- and mid-capitalization
companies may have greater price volatility, lower trading volume and less liquidity than large-capitalization
companies.
• Exchange Traded Funds (ETFs): While investing in ETFs has similar risks as investing in individual equities,
ETFs typically invest in a diverse group of securities. The level of diversification varies by ETF. While ETFs
reduce the effects of concentration risk as compared to investing in a single security, certain ETFs are
susceptible to industry, commodity or country risk. Investing in a diverse selection of ETFs may help to reduce
this risk. Another important factor to consider with ETFs is that the portfolio of securities in which they invest
are typically not actively managed. Leveraged and Inverse ETFs bear unique risks that investors who wish to
trade in these securities must understand; due to the significant risk involved in these securities, Lincoln
Investment will approve their use only on an exception basis.
• Buffer ETFs, also known as defined outcome ETFs, use options contracts to insure against some losses while
capturing some gains. The primary caveat with buffer ETFs is that, while they provide downside protection,
they also limit an asset’s returns. Additionally, buffer ETFs have slightly higher fees than traditional ETFs.
For example, a buffer ETF could hypothetically offer 50% protection against loss with a 7% upside cap. This
means that you are shielded from losses if the market drops by up to 50%, but, if the market goes up 20%, you
are still only entitled to a 7% return. A new cap is established at the beginning of each Target Outcome Period
and is dependent on prevailing market conditions. As a result, the cap may rise or fall from one Target Outcome
Period to the next and is unlikely to remain the same for consecutive Target Outcome Periods. A buffer ETF
will not participate in gains beyond the cap. In the event an investor purchases shares after the first day of a
Target Outcome Period and the ETF has risen in value to a level near the cap, there may be little or no ability
for that investor to experience an investment gain on their shares; however, the investor will remain vulnerable
to downside risk. A buffer ETF’s investment strategy is designed to deliver returns if shares are bought on the
first day and are held until the end of the Target Outcome Period subject to the cap. There can be no guarantee
that a target outcome fund will be successful in its strategy to buffer against losses. A shareholder may lose their
entire investment. In the event an investor purchases shares after the first day of the target outcome period
defined in the fund's prospectus ("Target Outcome Period") or sells shares prior to the end of the Target
Outcome Period, the buffer that a fund seeks to provide may not be available.
• Fixed Income Investments: One of the most important risks associated with fixed income securities is interest
rate risk, the risk encountered in the relationship between bond prices and interest rates. The price of a bond will
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change in the opposite direction of movements in prevailing interest rates. For example, as interest rates rise,
bond prices will generally fall. If an investor has to sell a bond prior to the maturity date, an increase in interest
rates could mean that the bondholder will experience a capital loss (i.e., selling the bond below its original
purchase price).
Reinvestment risk is the risk that the interest rate at which the interim cash flows can be reinvested will decline
and thus reinvestments will receive a lower interest rate. Reinvestment risk is greater for longer holding periods.
Default risk is commonly referred to as “credit risk” and is based on the probability that the issuer of the debt
obligation may default. Default risk is rated by quality ratings assigned by commercial rating companies.
Call risk is the risk related to call provisions on debt obligations. You should be aware of four risks associated
with call provisions.
1) The cash flow patterns of callable bonds are not known with certainty.
2) Since the issuer will typically exercise their right to call the bonds when interest rates have dropped,
you may be exposed to reinvestment risk. You would have to reinvest the proceeds after the bond is
called at relatively lower interest rates.
4)
3) The potential for capital appreciation of a callable bond is reduced relative to that of a non-callable
bond, because its price may not rise much above the price at which the issuer can call the issue.
If the issue is purchased at a premium, you may lose the difference between the purchase price and call
price.
Inflation risk arises because the value of the cash flows being received from a debt obligation may actually lose
purchasing power over the course of time due to the effects of inflation.
Liquidity risk depends on the ease with which an asset can be sold at or near its current value. The best indicator
to measure an issue’s liquidity is the size of the spread between the bid price and the ask price quoted by a
dealer. A wider spread on the asset indicates a greater liquidity risk. If you plan on holding a bond until its
maturity date, liquidity risk is less of a concern.
Finally, exchange rate risk, which is encountered in non-dollar denominated bonds or bonds whose payments
occur in a foreign currency, has unknown U.S. currency cash flows. The dollar cash flows are dependent on the
exchange rate at the time the payments are received. For example, consider a bond whose coupon payment is
paid out in Japanese yen. If the yen depreciates relative to the U.S. dollar, fewer net dollars will be received.
Conversely, if the yen should appreciate relative to the U.S. dollar, the investor will benefit by receiving more
net dollars.
Debt funds may include mortgage-backed securities and Treasury Inflation-Protected Securities (“TIPS”).
Mortgage-backed securities are subject to greater declines in value than traditional fixed income securities. This
is primarily due to decreased prepayments when interest rates fall, which could lengthen the average life of a
security. TIPS can provide a hedge against inflation, which helps preserve the purchasing power of the
investment. Because of this inflation adjustment feature, inflation protected bonds typically have lower yields
than conventional fixed rate bonds. These bonds will likely decline in price during periods of deflation, which
could result in losses.
A number of fund companies are offering Floating Rate funds, also called Bank Loan funds. The fund invests
mainly in floating rate loans (sometimes referred to as “adjustable rate loans”) typically issued to below-
investment-grade companies. These loans may or may not hold a senior position in the capital structure of the
underlying U.S. and foreign corporations, partnerships or other business entities. Senior Loans may allow them
to have priority of claim ahead of (or at least as high as) other obligations of a borrower in the event of
liquidation and may be collateralized or uncollateralized. They typically pay interest at rates that float above, or
are adjusted periodically based on, a benchmark that reflects current interest rates. These funds are designed for
investors seeking to participate in the market for Senior Loans, which may have higher risks than conventional
debt securities. Investors should be willing to assume the greater risks of short-term share price fluctuations and
the special credit risks that are typical for a fund that invests mainly in below-investment-grade fixed income
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securities. The fund is not designed for investors needing an assured level of current income. Lincoln
Investment’s use of these securities in its managed portfolios is only in well-diversified portfolios, to minimize
the risks to the portfolio yet allow for the potential participation in the higher yields associated with these higher
risk investments.
•
International Investing: Investing in the global market can assist with diversification of a portfolio but it is
important to consider some of the unique risks with such a strategy. Funds purchased for your account may
invest in international securities. Each country has unique rules and regulations covering corporations and their
stock markets which offer investors varying degrees of protection. There are special risks associated with
foreign investing, including currency fluctuations, economic instability and political developments. Fluctuations
in foreign currency-denominated securities may be magnified by changes in foreign exchange rates. These risks
may be magnified in emerging markets.
• Options: Certain options strategies are highly specialized contracts based on securities and entail greater than
ordinary investment risks.
For further information regarding the risks associated with the portfolios managed by Lincoln Investment and its
Advisors and the best suited investment strategies for your account(s), please review the risk level of the Wrap Fee
Program portfolio you have selected as listed in the accompanying addendum to your investment advisory
agreement and your mutual fund prospectuses, or consult with your Advisor.
Item 7: Client Information Provided to Portfolio Managers
When your Wrap Fee Program account is opened, your Advisor will assist you in completing a confidential investor
profile containing personal and financial information such as your risk tolerance, investment objectives, net worth,
and investing time horizon. This information may be communicated to a portfolio manager, including Lincoln
Investment, or a Sub-Adviser, when the Wrap Fee Program offers custom portfolio management. It is important that
you contact your Advisor when there is a material life event that could affect or change your investment objectives
or financial needs and to confirm there have been no changes in your risk tolerance, investment objectives or
financial situation which would need to be communicated to the portfolio manager or Sub-Adviser.
Lincoln Investment, the IM&R Team, your Advisor, and any other portfolio manager(s) rely on the accuracy of the
information you provide to manage your account(s). You are responsible to notify your Advisor of any changes in
your financial situation or investment objectives.
Item 8: Client Contact with Portfolio Managers
You may contact and consult with Lincoln Investment, your Advisor, and the Sub-Advisers or portfolio managers in
the Wrap Fee Programs in writing, over the phone or electronically. Lincoln Investment and certain Sub-Advisers or
portfolio managers may hold regular conference calls to discuss investment strategies or current market events. In
general, you should contact Sub-Advisers or portfolio managers through, or together with, your Advisor so that the
financial advice you receive is consistent.
Item 9: Additional Information
Disciplinary Information
Provided below is a summary of legal or disciplinary events within the past ten years that may be material to your
evaluation of Lincoln Investment’s advisory business.
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January 27, 2016: Lincoln Investment signed a Letter of Acceptance, Waiver and Consent (“AWC”) with
FINRA. Without admitting or denying the findings, Lincoln Investment accepted a censure and $75,000 fine
relating to the supervisory review of consolidated reports produced by Lincoln Investment’s representatives
and provided to clients. Lincoln Investment further agreed to adopt and implement procedures reasonably
designed to enhance the enforcement of our supervisory systems and procedures to ensure effective review of
consolidated reports produced by representatives and provided to clients.
September 25, 2018: Lincoln Investment signed a Letter of Acceptance, Waiver and Consent (“AWC”) with
FINRA. Without admitting or denying the findings, Lincoln Investment, relating to its broker-dealer, accepted
a censure and $35,000 fine relating to Lincoln Investment’s failure to implement reasonably designed
surveillance procedures to monitor its registered representatives’ rates of effecting variable annuity exchanges
where the firm was not the broker of record for the variable annuity that was being exchanged. After FINRA
raised this issue, Lincoln Investment corrected its surveillance report to include all variable annuity exchanges.
December 10, 2020: Lincoln Investment signed a Letter of Acceptance, Waiver and Consent (“AWC”) with
FINRA. Without admitting or denying the findings, Lincoln Investment, relating to its broker-dealer, accepted
a censure and $35,000 fine relating to Lincoln Investment’s failure to implement reasonably designed
supervisory procedures or written supervisory procedures to monitor withdrawals or transmittal of funds from
customer accounts, and as a result, in the fall of 2017, impostors stole or attempted to steal customer funds by
requesting transfers from the accounts of two Lincoln Investment customers. Following its discovery of these
events, Lincoln Investment took remedial measures to address the deficiencies in its supervisory system.
Your Advisor should provide along with this brochure a Form ADV 2B Brochure Supplement (“Form ADV 2B
Brochure Supplement” or “Financial Professional BIO Brochure”) that describes your Advisor’s education, business
experience, professional designations and material legal or disciplinary history, if any. For further information
regarding Lincoln Investment's disciplinary events you may go to www.adviserinfo.sec.gov or
https://brokercheck.finra.org and search for Lincoln Investment Planning, LLC.
Other Financial Industry Activities and Affiliations
Broker-Dealer and Insurance Agency
In addition to being a registered investment adviser, Lincoln Investment is also a registered broker-dealer and
an insurance agency. This presents a conflict of interest. Please refer to the "Other Compensation to Lincoln
Investment and Our Conflicts of Interest" section under Item 4 of this brochure for information regarding
Lincoln Investment's conflicts of interests as a broker-dealer and insurance agency and how we address these
conflicts.
Advisors’ Other Business Activities and Affiliations
Lincoln Investment's Advisors are primarily independent contractors, many of whom hold themselves out to
the public under a name other than Lincoln Investment and offer other financial services independent of
Lincoln Investment, such as life, health, disability, long term care and fixed annuity insurance products, real
estate, and business planning services. A few of our Advisors may also be qualified lawyers and accountants or
hold certain professional designations not required by us to conduct business through Lincoln Investment.
These services are offered independent of Lincoln Investment as outside business activities and Lincoln
Investment assumes no responsibility or supervision over these activities. Please refer to the "Other
Compensation to Lincoln Investment and Our Conflicts of Interest" section under Item 4 of this brochure, or
refer to your Advisor’s ADV 2B Brochure Supplement, for more information regarding outside business
activities and how we address these conflicts. You may go to www.adviserinfo.sec.gov or
https://brokercheck.finra.org for further information regarding your Advisor’s other business activities or
affiliations.
Independent Registered Investment Advisers
Lincoln Investment permits certain Advisors to maintain or affiliate with an independent registered investment
advisory firm which may offer advisory services similar to Lincoln Investment or its affiliate, Capital
Analysts. Such independent registered investment advisory firms are unaffiliated with Lincoln Investment and
Capital Analysts. These services are offered independent of Lincoln Investment and Capital Analysts as
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private securities transactions. Your Advisor can be associated with Lincoln Investment, Capital Analysts, or
an unaffiliated registered investment adviser as an investment adviser representative, and/or associated with
Lincoln Investment as a registered representative of Lincoln Investment’s broker-dealer. As such, your
Advisor can be in a position to offer you advisory services under Lincoln Investment, Capital Analysts, the
unaffiliated independent registered investment advisory firm, and brokerage services under Lincoln
Investment’s broker-dealer, or all of the above.
Advisors affiliated with other registered investment advisory firms must provide to their clients that firm’s
Form ADV Part 2A, applicable supplements, advisory agreements and disclosures if you are opening an
account with such other investment advisory firm. To inquire as to whether your Advisor is affiliated with a
separate registered investment advisory firm, it will be listed on their Financial Professional BIO Brochure
(Form ADV Part 2B), a copy of which they are required to provide to you, or you may go to
www.adviserinfo.sec.gov or https://brokercheck.finra.org.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics
As an investment adviser, Lincoln Investment has established a Code of Ethics under which all Lincoln
Investment supervised employees and Advisors must comply. In our capacity as an investment adviser,
Lincoln Investment owes a fiduciary duty to our investment advisory clients and is held to legal standards
under applicable federal and state securities laws. Lincoln Investment has a fiduciary responsibility to (1)
provide investment advice that the advisor believes is in the best interest of the client; (2) place clients interest
above the interests of Lincoln Investment and your advisor by providing full and fair disclosure of all material
facts and conflicts of interest to clients, and (3) conduct all personal securities transactions consistent with
Lincoln Investment's Code of Ethics.
Lincoln Investment's Advisors are held to a professional standard that requires them to avoid any abuse of their
position of trust and responsibility, not take inappropriate advantage of their positions, comply with applicable
securities laws and regulations, and maintain confidentiality of client's financial circumstances.
You may request a full copy of Lincoln Investment's Code of Ethics from your Advisor or Lincoln
Investment's Compliance Department at (800) 242-1421, ext. 4300.
Participation or Interest in Client Transactions and Personal Trading
Lincoln Investment, its Advisors, members of the IM&R Team, and employees may buy or sell for themselves
securities that are also recommended to clients. This presents a conflict of interest because trading by an
Advisor or employee, including members of the IM&R Team, in a personal securities account in the same
security prior to placing client trades can disadvantage the client. Lincoln Investment addresses this conflict of
interest by requiring in its Code of Ethics that Lincoln Investment Advisors and employees, including the
IM&R Team, must report certain personal securities transactions and holdings to Lincoln Investment.
In addition, Lincoln Investment’s Code of Ethics requires that the Advisor and his or her employees must give
first priority to client securities purchases and sales over their own personal transactions in the same security.
This means that any transaction by the Advisor or his/her employee must be placed either simultaneously with
your transaction in the same security (i.e., aggregating the orders and sharing in the same price and execution
costs) or after all client trades for that security are placed on the same trading day. While the latter will not
guarantee that you will receive the best price, it does establish that the client trades will occur at the same time
as or before that of the Advisor or his/her employees. At no time may an Advisor participate in the profits or
losses of an investor's account. Personal trading accounts of Advisors are monitored by Lincoln Investment to
ensure compliance.
Other than as described in its Code of Ethics and Insider Trading policies and procedures, Lincoln Investment
does not impose on itself or any person associated with it any restrictions in connection with the purchase or
sale, directly or indirectly, of investments for his or her own account.
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Brokerage Practices
Your advisor will recommend a platform based on the type of account you wish to open (brokerage or
advisory), the type of securities you wish to invest in (mutual funds only or exchange traded securities), and
the advisory programs that are available on that platform through Lincoln Investment.
Some advisory services offered by Lincoln Investment specify one or more custodians or clearing firms,
including Pershing, where the assets must reside in order for the advisory services to be engaged. For many of
these services, this allows Lincoln Investment the capability to have ongoing access to the assets for trading
and viewing purposes. Lincoln Investment acts as introducing broker-dealer for advisory accounts held at
Pershing, with whom Lincoln Investment maintains its primary clearing arrangement. When Lincoln
Investment is recommending that your account and your transactions be placed with us as introducing broker-
dealer for accounts held at Pershing or another broker-dealer, we cannot guarantee that Pershing will be the
lowest cost platform for you, or that you will receive the most favorable execution on your transactions, which
can cost you more money. Not all investment advisers require the use of a specific broker-dealer/custodian.
In its sole discretion, Lincoln Investment can approve the use of account custodians other than Pershing. Third-
party custodians have their own platform, administrative and trading costs to which you will be subject. If a
client should request, and Lincoln Investment approve, the use of a broker-dealer/custodian other than Pershing
for securities transaction execution, the client should be aware that Lincoln Investment will generally be unable
to negotiate commissions or other fees and charges for the client’s account. Therefore, we cannot guarantee
that the platform recommended to you will be the lowest cost platform for you.
Please consult with your Advisor regarding which broker-dealer/custodians may be required for the advisory
service(s) you wish to select or invest. When selecting a custodian, Lincoln Investment can consider certain
factors, such as reasonableness of applicable fees, products and services offered, and other qualitative factors
such as the broker-dealer’s execution capability, financial responsibility, and responsiveness.
Brokerage or custodial account fees and/or transaction charges, if any, are disclosed to you at the time your
account is established for accounts held at Pershing. Pershing has its own platform, administrative and
transaction-related fees. For platforms other than Pershing, you should review the applicable platform
application, applicable fund prospectus and/or any additional disclosure documents and agreements which
outline the costs specific to the platform. Brokerage or custodial account fees and/or transaction charges can
change over time. You should review the specific platform disclosure documents. Lincoln Investment shares in
fees from certain clearing firms, such as Pershing. Please refer to the "Other Compensation to Lincoln
Investment and Our Conflicts of Interest" section under Item 5 of this brochure for information regarding
Lincoln Investment's conflicts of interests with regard to different platforms, including Pershing. For a
description of trading and administrative fees associated with where your account will be held, view the
specific platform disclosure document for your account found at www.lincolninvestment.com/Disclosures.
Trade Aggregation Policy
Offering advisory services to clients includes an obligation on the part of Lincoln Investment and its Advisors
to ensure that the allocation of investment opportunities or trades among its various client accounts, as well as
accounts in which it (or its affiliates) has a proprietary interest, is performed in a manner that is fair and
equitable in its treatment of all clients and, wherever possible, avoids conflicts of interest.
Therefore, Lincoln Investment has adopted an Aggregated Trade Allocation Policy to be used by Lincoln
Investment and Advisors who have been granted discretionary authority by their clients when placing orders in
the same security on the same day for one or more clients or accounts. By aggregating orders, Advisors ensure
that all clients receive that same price for the security on the same day. This policy is intended to prevent
favoritism of one client over another and establish a rational and predictable fashion for the allocation of trade
pricing on a given day for a given security.
Trades in the following situations will typically be aggregated:
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• Lincoln Investment or the Advisor recognizes ahead of time that he/she will be buying or selling the
same security in more than one client account on the same day;
• Lincoln Investment or the Advisor reasonably believes that aggregating may facilitate a better execution
price for all clients; and
• The securities involved are exchange-traded rather than open-ended funds or annuity sub accounts.
Trades in the following situations will not typically be aggregated:
• Where prohibited by or inconsistent with the client’s investment management agreement;
• The trade is a result of the implementation of a change of investment strategy for a specific client;
• The trade is part of a new client’s account allocation;
• The trade is a result of rebalancing to an asset allocation policy or pursuant to an account review with the
client; and/or
• Lincoln Investment or the Advisor reasonably believes that aggregating orders would adversely impact
price and/or best execution for the client.
If the security to be purchased in aggregate cannot be obtained in the total quantity required, the allocation of
that security will be made on a pro rata basis determined by the ratio of the quantity obtained to the share
quantity required to implement the investment strategy. Each client would participate in the order at the
average price for all of the transactions on a given day.
If implementing the trade requires transactions over several days, each day’s execution shares and average
price on all executions for that day shall be allocated by the end of each trading day or no later than the next
trading day. In the course of executing an aggregated trade, a list of clients’ accounts and shares to be bought
or sold is to be prepared. This is to be used in allocating the trade and the list is to be kept as a record with the
original aggregated trade order. Allocation of shares, prices, and costs shall be done on a timely basis, in no
event to exceed 24 hours following execution. Lincoln Investment and your Advisor shall not receive any
additional compensation for aggregating trades.
If implementing the trade requires transactions over several days, each day’s execution shares and average price on
all executions for that day shall be allocated by the end of each trading day or no later than the next trading day. In
the course of executing an aggregated trade, a list of clients’ accounts and shares to be bought or sold is to be
prepared. This is to be used in allocating the trade and the list is to be kept as a record with the original aggregated
trade order. Allocation of shares, prices, and costs shall be done on a timely basis, in no event to exceed two (2)
trading days following execution. Lincoln Investment and your Advisor shall not receive any additional
compensation for aggregating trades.
Lincoln Investment’s advisory assets at Pershing comprise the majority of the firm’s managed assets. In order to
minimize financial impact to the majority of clients, the trade allocation policy will not apply in the event of
significant market volatility and Lincoln Investment will give priority to advisory assets at Pershing.
Discretionary model portfolios managed by Lincoln Investment are generally traded in concert as described above;
however, there are certain portfolios that are managed by Lincoln Investment on a custom basis which trade
separately from the models.
Review of Accounts
Account Review Policies and Procedures
Your Advisor is responsible to ensure that the recommended advisory service is in your best interest. Many of
our programs are managed to defined levels of risk, so choosing the appropriate risk level or tolerance for
market fluctuation and potential loss of investment is an important part of your decision. Furthermore, the
Financial Advisor Fee portion of your fees compensates your Advisor for his or her services. If Lincoln
Investment or your Advisor have been granted full discretionary trading authority over your advisory account,
Lincoln Investment or your Advisor will provide ongoing monitoring and will make changes in your account
as deemed necessary. For all other advisory accounts, you and your Advisor will review your advisory
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account’s objectives, investments and performance relative to your objectives and financial situation at least
annually to allow your Advisor the opportunity to recommend changing or maintaining the objectives or
investments in your account. It is important therefore that you take the time to speak with your Advisor
regarding your financial objectives and needs and particularly when there is a material life event that could
affect or change your investment objectives or financial needs. For a full description of discretionary authority
on your account, please see your investment advisory agreement.
Lincoln Investment has procedures in place to supervise the investment advisory activities of its Advisors. If
you have any questions about the trading or recommendations in your account, please call your Advisor's
Designated Supervisor.
Lincoln Investment’s IM&R Team routinely reviews the advisory services managed, sponsored, and/or offered
by Lincoln Investment’s Sub-Advisers. A description of the IM&R Team is provided in the supplement at the
end of this brochure. The IM&R Team performs the following roles on Lincoln Investment’s behalf:
• The management of all Lincoln Investment managed model portfolios
• The selection of advisory services offered by Lincoln Investment
• The monitoring of Sub-Advisers and Third-party money managers offered by Lincoln Investment
• The removal of Sub-Advisers and Third-party money managers advisory services offered by Lincoln
Investment
Written Reports
At minimum, you will receive a quarterly account statement from the custodian who carries your account. This
statement will reflect all transactions that have occurred in your account as well as identify fees, including the
advisory fee, deducted from your account. This is the most important statement you will receive and should be
reviewed immediately upon receipt to ensure accuracy in your holdings and transactions.
Some Advisors and advisory services may also provide you supplemental advisory reports which may include
performance reports, aggregated account reviews, or a portfolio snapshot. These supplemental reports,
typically generated on a quarterly, semiannual or annual basis, are made available to you either electronically
or will be delivered to you. These supplemental reports are provided as a service to you and should not replace
your custodial statement(s). We urge you to compare these supplemental reports to the account statements you
receive. If you find any discrepancies, please contact your Advisor or Lincoln Investment.
Client Referrals and Other Compensation
Advisors and Lincoln Investment can act as a promoter and introduce you to a third-party money manager. In
Promoter relationships, we are not acting as a Co-Adviser. For this introduction, the third-party money manager will
pay Lincoln Investment a Promoter/Referral Fee, which we will share with your Advisor. This fee, which is
typically an ongoing portion of the fee collected from you by the manager, must be disclosed to you at the time of
the introduction. Please refer to the disclosure provided to you at the time of the referral to determine the fee paid to
Lincoln Investment and your Advisor. Please review the third-party money manager’s ADV Part 2A for more
information about their advisory fees. On occasion, Lincoln Investment compensates or permits an Advisor to
compensate an outside party (for example, an attorney, accountant, bank or credit union) for client referrals to one of
our advisory services. Other than banks and credit unions, no new relationships in which Lincoln Investment
compensates or permits an Advisor to compensate an outside party for client referrals are permitted.
For details regarding other compensation received by Lincoln Investment and your Advisor and associated conflicts
of interest, see Item 4: Services, Fees and Compensation in the section titled "Other Compensation to Lincoln
Investment and Our Conflicts of Interest."
Custody
Advisers Act Rule 206(4)-2 (the “Custody Rule”) sets forth extensive requirements regarding possession or custody
of client funds or securities. The Custody Rule is designed to ensure that registered investment advisers with access
to client assets (securities or cash) establish procedures to protect the assets from misappropriation, conversion,
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insolvency of the adviser or unauthorized reallocation of securities among clients. Lincoln Investment’s advisory
account assets are held with unaffiliated third-party custodians who serve as qualified custodians and provide clients
with, at minimum, quarterly account statements. Pershing acts as the custodian for the majority of Lincoln
Investment’s advisory programs. For some advisory assets, the firm is deemed to have custody and is therefore
required to undergo an annual surprise exam.
If you have advisory assets held at Pershing or another qualified custodian, you will receive, at minimum, a
quarterly statement from the qualified custodian(s) of your advisory assets. We urge you to carefully review these
statements and compare them to any reports provided to you by Lincoln Investment or your Advisor. The
information in these reports may vary from your custodial statements based on accounting procedures and reporting
dates. Please contact your Advisor or Lincoln Investment regarding any statement discrepancies.
Investment Discretion
Depending on the advisory service chosen, Lincoln Investment, its Advisors, a third-party manager and/or an
overlay manager may have discretionary authority to determine which securities shall be bought and sold, and the
total amount to be bought or sold in your advisory account(s). This authorization does not grant Lincoln Investment,
its Advisors, or, if applicable, any third-party manager or overlay manager, the right to withdraw any funds or
securities from your advisory account(s), except as specifically authorized in your advisory agreement for the
deduction of advisory fees. Your advisory agreement or account application will identify whether and to what extent
you are giving discretionary trading authority for your advisory account(s) to Lincoln Investment, your Advisor, a
third-party money manager or an overlay manager.
Voting Client Securities
Lincoln Investment and its Advisors may not, and do not, accept authority to vote clients’ proxies for any securities
in an advisory or non-advisory service. BNYMA will vote proxies received on behalf of assets allocated to the
Premier Asset Management, Select Manager, Manager Access, UMA, and PPM Programs where BNYMA acts as
Overlay Manager or, in the case of the UMA Program, UMA Overlay Manager. For all other programs and
portfolios, neither Lincoln Investment, the IM&R Team, BNYMA nor your Advisor will recommend how to vote
nor will Lincoln Investment, the IM&R Team, BNYMA or your Advisor vote any proxies for your account(s).
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Form ADV Part 2B Brochure Supplement
Lincoln Investment Planning, LLC
Form ADV Part 2B Brochure Supplement
As of March 31, 2026
Principal Office:
601 Office Center Drive
Fort Washington, PA 19034
Investment Management & Research
Shashi Mehrotra, CFA®
Christopher J. Surrichio, CFA®
Gerald E. Burhop, CFA®, CIPM®
Brian Moran
Steven E. Mueller, CFA®
This brochure supplement provides you with information about the five (5) members of the Investment Management
& Research Team (“IM&R Team”) of Lincoln Investment Planning, LLC (“Lincoln Investment”) who have the
most significant day-to-day management responsibilities for the Lincoln Investment managed portfolios. This
information supplements the information contained in the Lincoln Investment Form ADV 2A and/or Wrap Fee
Program brochure, which you should have received.
If you have any questions about the contents of this brochure supplement, please contact us at (800) 242-1421.
Additional information about each of the members of the IM&R Team is available through the U.S. Securities and
Exchange Commission at www.adviserinfo.sec.gov.
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Shashi Mehrotra, CFA®
EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE
Year of Birth: 1966
Education
Master of Business Administration, Florida Atlantic University, 1994
Bachelor of Engineering, Osmania University, 1989
Business Experience
Lincoln Investment Planning, LLC, July 2025 – Present, Senior Vice President and Chief Investment Officer
Lincoln Investment Planning, LLC, May 2019 – July 2025, Senior Vice President and Chief Investment Strategist
Capital Analysts, LLC, July 2025 – Present, Senior Vice President and Chief Investment Officer
Capital Analysts, LLC, September 2019 – Present, Investment Adviser Representative
Lincoln Investment Planning, LLC, June 2019 – Present, Investment Adviser Representative
Lincoln Investment Planning, LLC, January 2017 – Present, Registered Representative
Legend Advisory, LLC, April 2011 – September 2019, Investment Adviser Representative
Legend Equities Corporation, January 1996 – January 2017, Registered Representative
Legend Advisory, LLC, July 1995 – September 2019, Chief Investment Officer/Chief Operating Officer
Professional Licenses/Designations
Mr. Mehrotra holds general securities principal and general securities representative licenses with Lincoln
Investment.
In addition, Mr. Mehrotra maintains the following professional designation:
Chartered Financial Analyst® (CFA®)
Designation Status: Currently offered and recognized by the issuing organization
Issuing Organization: CFA Institute
Prerequisites/Experience Required: Candidate must meet one of the following requirements: Undergraduate
degree and four years of professional experience involving investment decision-making, or four years
qualified work experience (full time, but not necessarily investment related)
Education Requirements: Self-study program (250 hours of study for each of the three levels)
Exam Type: Three course exams
Continuing Education Requirements: None
DISCIPLINARY INFORMATION
Mr. Mehrotra has no material legal or disciplinary events to report.
OTHER BUSINESS ACTIVITIES
Mr. Mehrotra sits on the Board of Directors of Aqua Pulsar, a water-engineering company, where he assists with
strategic financial and investment decisions. You are under no obligation as an investment advisory client to
purchase any outside products or services that Mr. Mehrotra may offer.
ADDITIONAL COMPENSATION
Generally, members of the IM&R Team IM&R Team are compensated through salaries and bonuses. They may be
compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan.
Salaries are fixed annually and are driven by the marketplace. Compensation is not affected by an increase in
advised assets.
Please see the Services, Fees and Compensation section of the accompanying Form ADV 2A and/or Wrap Program
brochure. This section describes in detail other potential forms of compensation in addition to the advisory fee paid
to Lincoln Investment.
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SUPERVISION
The individual responsible for monitoring the advisory activities of Mr. Mehrotra is Ed Forst, Chief Executive
Officer of Lincoln Investment Planning, LLC and Capital Analysts, LLC. Mr. Forst or his designee is responsible to
review the duties, responsibilities and trading assigned to Mr. Mehrotra. If you have any questions about the trading
in your account, please call Mr. Forst at (800) 242-1421.
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March 2026
Christopher J. Surrichio, CFA®
EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE
Year of Birth: 1970
Education
Bachelor of Arts, Economics, Boston College, 1992
Business Experience
Lincoln Investment Planning, LLC, July 2025 – Present, Deputy Chief Investment Officer
Capital Analysts, LLC, July 2025 – Present, Deputy Chief Investment Officer
Capital Analysts, LLC, June 2012 – July 2025, Vice President and Portfolio Manager
Capital Analysts, LLC, June 2012 – Present, Investment Adviser Representative
Lincoln Investment Planning, LLC, June 2012 – Present, Investment Adviser Representative and Registered
Representative
Capital Analysts, Incorporated, 2002 – June 2012, Vice President
Professional Licenses/Designations
Mr. Surrichio holds general securities principal, general securities representative and research analyst licenses with
Lincoln Investment, as well as through its affiliated RIA, Capital Analysts, LLC.
In addition, Mr. Surrichio maintains the following professional designations:
Chartered Financial Analyst® (CFA®)
Designation Status: Currently offered and recognized by the issuing organization
Issuing Organization: CFA Institute
Prerequisites/Experience Required: Candidate must meet one of the following requirements:
Undergraduate degree and four years of professional experience involving investment decision-making, or
four years qualified work experience (full time, but not necessarily investment related)
Educational Requirements: Self-study program (250 hours of study for each of the three levels)
Examination Type: Three course exams
Continuing Education/Experience Requirements: None
DISCIPLINARY INFORMATION
Mr. Surrichio has no material legal or disciplinary events to report.
OTHER BUSINESS ACTIVITIES
The IM&R Team is responsible for the asset management programs managed by Lincoln Investment and Capital
Analysts, LLC, an affiliated investment adviser. The management of portfolios for both investment advisers may
create a conflict.
Mr. Surrichio has no other business activities to report.
ADDITIONAL COMPENSATION
Generally, members of the IM&R Team IM&R Team are compensated through salaries and bonuses. They may be
compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan.
Salaries are fixed annually and are driven by the marketplace. Compensation is not affected by an increase in
advised assets.
Please see the Services, Fees and Compensation section of the accompanying Form ADV 2A and/or Wrap Program
brochure. This section describes in detail other potential forms of compensation in addition to the advisory fee paid
to Lincoln Investment or Capital Analysts.
SUPERVISION
The individual responsible for monitoring the advisory activities of Mr. Surrichio is Shashi Mehrotra, Senior Vice
President and Chief Investment Officer. Mr. Mehrotra or his designee is responsible to review the duties,
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responsibilities and trading assigned to Mr. Surrichio. If you have any questions about the trading in your account,
please call Mr. Mehrotra at (561) 307-0906.
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March 2026
Gerald E. Burhop, CFA®, CIPM®
EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE
Year of Birth: 1964
Education
Master of Business Administration, Finance, Temple University, 1998
Bachelor of Science, Agricultural Journalism/Advertising, University of Wisconsin-Madison, 1988
Business Experience
Lincoln Investment Planning, LLC, 2002 – Present, Vice President and Portfolio Manager
Lincoln Investment Planning, LLC, October 1999 – Present, Registered Representative
Lincoln Investment Planning, LLC, April 2011 – Present, Investment Adviser Representative
Lincoln Investment Planning, LLC, March 1999 – 2002, Mutual Fund Financial Analyst
Capital Analysts, LLC, March 2014 – Present, Investment Adviser Representative
Professional Licenses/Designations
Mr. Burhop holds general securities principal and general securities representative licenses with Lincoln Investment,
as well as through its affiliated RIA, Capital Analysts, LLC.
In addition, Mr. Burhop maintains the following professional designations:
Chartered Financial Analyst® (CFA®)
Designation Status: Currently offered and recognized by the issuing organization
Issuing Organization: CFA Institute
Prerequisites/Experience Required: Candidate must meet one of the following requirements:
Undergraduate degree and four years of professional experience involving investment decision-making, or
four years qualified work experience (full time, but not necessarily investment related)
Educational Requirements: Self-study program (250 hours of study for each of the three levels)
Examination Type: Three course exams
Continuing Education/Experience Requirements: None
Certificate in Investment Performance Measurement™ (CIPM®)
Designation Status: Currently offered and recognized by the issuing organization
Issuing Organization: CFA Institute
Prerequisites/Experience Required: Candidate must meet one of the following requirements: Two years of
professional experience “substantially entailing performance-related activities,” or four years of investment
industry work experience
Educational Requirements: Self-study program (100 or more hours of study for each of the two levels)
Examination Type: Two level exams (Principles and Expert)
Continuing Education/Experience Requirements: Complete and record 15 hours of qualifying activities
annually
DISCIPLINARY INFORMATION
Mr. Burhop has no material legal or disciplinary events to report.
OTHER BUSINESS ACTIVITIES
The IM&R Team is responsible for the asset management programs managed by Lincoln Investment and Capital
Analysts, LLC, an affiliated investment adviser. The management of portfolios for both investment advisers may
create a conflict.
Mr. Burhop has no other business activities to report.
ADDITIONAL COMPENSATION
Generally, members of the IM&R Team are compensated through salaries and bonuses. They may be compensated
with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed
annually and are driven by the marketplace. Compensation is not affected by an increase in advised assets.
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Please see the Services, Fees and Compensation section of the accompanying Form ADV 2A and/or Wrap Program
brochure. This section describes in detail other potential forms of compensation in addition to the advisory fee paid
to Lincoln Investment or Capital Analysts.
SUPERVISION
The individual responsible for monitoring the advisory activities of Mr. Burhop is Shashi Mehrotra, Senior Vice
President and Chief Investment Officer. Mr. Mehrotra or his designee is responsible to review the duties,
responsibilities and trading assigned to Mr. Burhop. If you have any questions about the trading in your account,
please call Mr. Mehrotra at (561) 307-0906.
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March 2026
Brian Moran
EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE
Year of Birth: 1967
Education
Master of Business Administration, Drexel University, 2012
Bachelor of Science, Economics, University of Pennsylvania, 1990
Business Experience
Capital Analysts, LLC, May 2015 – Present, Vice President of Trading and Portfolio Manager
Capital Analysts, LLC, June 2012 – May 2015, Institutional Trading Manager
Capital Analysts, LLC, June 2012 – Present, Investment Adviser Representative
Lincoln Investment Planning, LLC, June 2012 – Present, Registered Representative
Lincoln Investment Planning, LLC, August 2012 – Present, Investment Adviser Representative
Capital Analysts, Incorporated, 2001 – June 2012, Institutional Trading Manager
Professional Licenses/Designations
Mr. Moran holds general securities principal, general securities representative, municipal securities principal, and
options principal licenses with Lincoln Investment, as well as through its affiliated RIA, Capital Analysts, LLC.
DISCIPLINARY INFORMATION
Mr. Moran has no material legal or disciplinary events to report.
OTHER BUSINESS ACTIVITIES
The IM&R Team is responsible for the asset management programs managed by Lincoln Investment and Capital
Analysts, LLC, an affiliated investment adviser. The management of portfolios for both investment advisers may
create a conflict.
Mr. Moran has no other business activities to report.
ADDITIONAL COMPENSATION
Generally, members of the IM&R Team are compensated through salaries and bonuses. They may be compensated
with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed
annually and are driven by the marketplace. Compensation is not affected by an increase in advised assets.
Please see the Services, Fees and Compensation section of the accompanying Form ADV 2A and/or Wrap Program
brochure. This section describes in detail other potential forms of compensation in addition to the advisory fee paid
to Lincoln Investment or Capital Analysts.
SUPERVISION
The individual responsible for monitoring the advisory activities of Mr. Moran is Shashi Mehrotra, Senior Vice
President and Chief Investment Officer. Mr. Mehrotra or his designee is responsible to review the duties,
responsibilities and trading assigned to Mr. Moran. If you have any questions about the trading in your account,
please call Mr. Mehrotra at (561) 307-0906.
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March 2026
Steven E. Mueller, CFA®
EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE
Year of Birth: 1982
Education
Bachelor of Science, Finance, Temple University, 2012
Business Experience
Lincoln Investment Planning, LLC, September 2025 – Present, Assistant Portfolio Manager
Lincoln Investment Planning, LLC, August 2017 – September 2025, Senior Research Analyst
Lincoln Investment Planning, LLC, August 2014 – August 2017, Research Analyst
Lincoln Investment Planning, LLC, September 2013 – August 2014, Internal Wholesaler, Asset Management
Lincoln Investment Planning, LLC, September 2013 – Present, Investment Adviser Representative
Lincoln Investment Planning, LLC, March 2013 – Present, Registered Representative
Professional Licenses/Designations
Mr. Mueller holds general securities principal, general securities representative, and uniform combined state law
examinations with Lincoln Investment.
Chartered Financial Analyst® (CFA®)
Designation Status: Currently offered and recognized by the issuing organization
Issuing Organization: CFA Institute
Prerequisites/Experience Required: Candidate must meet one of the following requirements: Undergraduate
degree and four years of professional experience involving investment decision-making, or four years
qualified work experience (full time, but not necessarily investment related)
Education Requirements: Self-study program (250 hours of study for each of the three levels)
Examination Type: Three course exams
Continuing Education/Experience Requirements: None
DISCIPLINARY INFORMATION
Mr. Mueller has no material legal or disciplinary events to report.
OTHER BUSINESS ACTIVITIES
The IM&R Team is responsible for the asset management programs managed by Lincoln Investment and Capital
Analysts, LLC, an affiliated investment adviser. The management of portfolios for both investment advisers may
create a conflict.
Mr. Mueller has no other business activities to report.
ADDITIONAL COMPENSATION
Generally, members of the IM&R Team are compensated through salaries and bonuses. They may be compensated
with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed
annually and are driven by the marketplace. Compensation is not affected by an increase in advised assets.
Please see the Services, Fees and Compensation section of the accompanying Form ADV 2A and/or Wrap Program
brochure. This section describes in detail other potential forms of compensation in addition to the advisory fee paid
to Lincoln Investment or Capital Analysts.
SUPERVISION
The individual responsible for monitoring the advisory activities of Mr. Mueller is Christopher J. Surrichio, Deputy
Chief Investment Officer. Mr. Surrichio or his designee is responsible to review the duties, responsibilities and
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trading assigned to Mr. Mueller. If you have any questions about the trading in your account, please call Mr.
Surrichio at (215) 881-7733.
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March 2026
Additional Brochure: LINCOLN INVESTMENT PLANNING, LLC FORM ADV PART 2A BROCHURE (2026-03-31)
View Document Text
Item 1: Cover Page Form ADV Part 2A
Lincoln Investment Planning, LLC
Investment Advisory Disclosure Brochure
As of March 31, 2026
Principal Office:
601 Office Center Drive, Suite 300
Fort Washington, PA 19034
(800) 242-1421
You may also visit us on the web at www.lincolninvestment.com.
This Brochure provides information about the qualifications and business practices of Lincoln Investment Planning,
LLC, a registered investment adviser with the U.S. Securities and Exchange Commission (SEC). If you have any
questions about the contents of this brochure, please contact us at (800) 242-1421. The information in this brochure
has not been approved or verified by the SEC or by any state securities authority. Furthermore, registration with the
SEC does not imply a certain level of skill or training.
Additional information about Lincoln Investment Planning, LLC is also available on the SEC's website at
www.adviserinfo.sec.gov.
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Item 2: Material Changes
This section provides us the opportunity to highlight for you the material changes to our Lincoln Investment
Planning, LLC Form ADV 2A and Form 2A Appendix I since our last annual amendment in March 2025.
This information is being provided so that you can continue to make informed decisions about the advisory services
provided to you by Lincoln Investment Planning, LLC.
The following is provided as an update to Lincoln Investment’s Form ADV 2A Item 5, Fees and
Compensation and Form ADV 2A Appendix I Item 4, Services, Fees and Compensation:
Other Compensation to Lincoln Investment and Our Conflicts of Interest
Lincoln Investment recognizes its fiduciary responsibility to place your interests above ours and that other
compensation received by us, or an affiliate, from other sources presents a conflict of interest and could be looked
upon by you as an incentive for us to recommend investment products or advisory services based on compensation
rather than on your financial needs. Below is a description of conflicts of interest that we have identified in the
conduct of our business that we believe may be material. With many of these conflicts, we have taken steps to
mitigate or reduce the conflict.
Understanding Share Classes in Lincoln Investment Advisory Accounts
Mutual funds are common investments for individuals. A mutual fund pools money from many investors and invests
the money in securities or other assets. A mutual fund has various expenses that are paid from fund assets. These
internal expenses are reflected in the fund's "expense ratio." Such expenses include fees paid to the adviser that
manages the fund, operational expenses, and fees paid to the brokers that sell shares of, and provide services to, the
fund. These are ongoing fees and expenses charged throughout the life of the mutual fund investment. Fees and
expenses are an important consideration in selecting a mutual fund because these charges lower an investor's returns.
A mutual fund frequently offers investors different "share classes." Each class will invest in the same "pool" or
portfolio of securities and other assets, but each class will have different fees and expenses and, therefore, different
returns. For example, some share classes have higher expense ratios because they pay brokers more for selling or
servicing that particular share class. In contrast, other share classes of the same fund may have lower internal fees
and expenses. A single mutual fund will often have share classes with different expense ratios, with the share classes
that have higher expense ratios generally having lower returns than share classes with lower expense ratios. In other
words, an individual investor may pay more, or less, for precisely the same mutual fund investment, depending on
the share class. These internal fees and expenses are in addition to any fees a broker may directly charge customers
on particular share classes, including transaction-related fees, such as surcharge fees, at the time of buying or selling
the fund shares, and are in addition to the investment advisory fee you will pay.
The expense ratio of a fund is disclosed in the fund’s prospectus and annual reports and generally reflects the annual
operating costs of the fund, assessed as a percentage of a fund’s average assets. The expense ratio within a mutual
fund share class can fluctuate from what is shown in a prospectus for the fund offering and annual report and can
vary over time and from year to year. A fund that was deemed to have a lower expense ratio at the time of purchase
may not actually maintain that expense ratio during the time that the fund is held and new fund share classes may
become available with different expense ratios.
Lincoln Investment looks at the “Prospectus Net Expense Ratio” as provided by a third-party data provider for each
mutual fund share class to determine the least expensive eligible share class. The Prospectus Net Expense Ratio is a
fund’s stated total annual operating expense percentage after any contractual fee waivers or other expense
reimbursements to the fund.
Lincoln Investment’s Share Class Selection Policy for Advisory Accounts
This share class selection policy applies to your advisory assets that are custodied at Pershing LLC (“Pershing”) and
for which Lincoln Investment and/or your financial professional initiate the trade and is described below. For your
advisory assets custodied at Pershing utilizing an overlay manager, the share class designated by Lincoln Investment
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is subject to the approval of your overlay manager. The overlay manager can choose to utilize a share class in your
account that differs from the policy outlined below. If applicable, please see your overlay manager’s Form ADV 2A
and/or Appendix I for additional details.
Although you are purchasing at net asset value of the fund, there are internal expenses built into every mutual fund
that can impact the performance of your investment over time. Regardless of whether you have selected a
discretionary or non-discretionary advisory program, share class selection for your mutual fund purchases within
your advisory account will be determined by Lincoln Investment. Share class expenses can vary across different
share classes of the same fund. In furtherance of its fiduciary duty to advisory clients, Lincoln Investment will seek
to select the least expensive share class available on the applicable custodial platform for the selected mutual fund
for which all of our retail advisory accounts will be eligible (except that money market mutual funds within the
Sweep Program and 403(b)7/457(b) accounts are treated differently, each as described below). For purposes of this
policy, the least expensive share class is defined as the share class of a mutual fund that has the lowest prospectus
net expense ratio as published by the third-party data provider (or a share class with a net expense ratio that is no
greater than ten basis points (0.10%) different than such share class with the lowest net expense ratio), subject to the
share classes’ investment minimums being appropriate for all of our retail advisory investors, obtaining investment
minimum waivers where they are available, and selecting a share class that is available to all investors regardless of
account tax type. In addition, due to specific mutual fund company constraints, situations will arise where Lincoln
Investment chooses a share class that does not have the lowest prospectus net expense ratio in that mutual fund in
order to remain consistent with the share classes of other mutual funds within a particular fund family available on
our platform.
Accounts on the Lincoln Workplace Retirement Solutions platform for 403(b)/457 accounts custodied at Pershing in
the Client Custom Portfolios (advisor-managed) program are subject to a No Surcharge Fund First (“NSFF”) policy,
as described below. The No Surcharge Fund First (“NSFF”) policy is applicable to Client Custom Portfolios
(advisor-managed) 403(b)/457(b) accounts only. Under the NSFF policy, for fund families that offer certain share
classes that assess a surcharge, Lincoln Investment will make available the share class with the least expensive
internal expense ratio that does not assess a surcharge fee. If the fund family does not offer a share class without a
surcharge fee, Lincoln Investment will make available the share class with the least expensive internal expense ratio
and the surcharge fee will be assessed. Generally, and subject to additional conditions, the designated share class
will be ascertained by designating the share class with the lowest internal expense ratio for which no surcharge fee
applies and all 403(b)/457(b) accounts on the Pershing platform will be eligible. Where all share classes of a mutual
fund assess a surcharge fee, that surcharge fee fund will remain available subject to the surcharge fee discussed
above and in the Lincoln Investment Trading Fees, Account Service Fees and Disclosures – Accounts Held on
Pershing Platform.
In addition to the share class selection factors described above, Lincoln Investment will also consider various other
factors when considering share class conversions in your advisory accounts, including but not limited to, whether
the fund will allow tax-free conversions, as well as whether there is a ten basis point (0.10%) or greater difference in
the expense ratio between the existing share class and the new, proposed share class. The fund share class used in a
discretionary Lincoln Investment Managed Model Portfolio can be different than the fund share class used in other
Lincoln Investment advisory accounts, including accounts managed by your financial professional, as a fund
minimum waiver may be available for discretionary Lincoln Investment managed model portfolios but not for other
types of advisory accounts, such as accounts managed by your financial professional. Most mutual funds offer
varying share classes, but all custodians may not make all share classes of a mutual fund available; therefore, the
designated share class selected by Lincoln Investment will likely vary across custodial platforms.
If the fund and share class selected includes a 12b-1 fee, Lincoln Investment will continue to credit back to your
advisory account any 12b-1 fee revenue received by the firm on behalf of your advisory assets to eliminate the
conflict of interest associated with the receipt of such revenue.
Lincoln Investment will review available mutual fund share classes periodically to identify share classes that must
be changed in order to align with this policy. If a different share class is identified that meets our policy criteria as
described herein, Lincoln Investment will initiate a share class conversion for all mutual fund investments in those
share classes. In addition, for accounts subject to the NSFF policy, if it is determined that a mutual fund share class
that does not assess a surcharge fee is available and meets our policy criteria as described above, Lincoln Investment
will initiate a share class conversion for all mutual fund investments in the surcharge fee share class to that no
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surcharge fee share class (except that money market mutual funds within the Sweep Program are treated differently,
as described below). Share class conversions will appear on your account statements. The ability and length of time
to affect a share class conversion will vary and is subject to prospectus requirements and custodial platform
approval. If you transfer-in shares of a mutual fund into an advisory account that are in a share class with a lower
internal expense ratio than the share class available in your advisory program, Lincoln Investment can convert your
mutual fund position to the share class of that fund that meets our policy criteria as described herein (including a
share class with a higher internal expense ratio). Lincoln Investment can also restrict additional purchases of a share
class and convert any grandfathered share class during a periodic review. For accounts subject to the NSFF policy, if
you transfer-in shares of a mutual fund that assesses a surcharge fee, Lincoln Investment will convert your mutual
fund position from a mutual fund share class that assesses a surcharge fee to a share class that does not assess a
surcharge fee, if available.
Not all mutual funds and share classes available to the investing public will be available to Lincoln Investment
and/or available for use in your advisory program. You should not assume that you are or will be invested in the
least expensive share class available, and the share class of a mutual fund offered by Lincoln Investment can have
higher expenses, and therefore lower returns. Additionally, Lincoln Investment has selected a higher-cost share class
with respect to the Dreyfus Government Cash Management Fund – Service Shares Sweep Product, which is the
designated sweep product for non-ERISA 403(b)7 and 457(b) plans and participant accounts and the designated
secondary sweep product for excess balances in the Dreyfus Insured Deposits L Sweep Product. There are less
expensive share classes of the same money market mutual fund available that would not provide revenue sharing
with the firm or would provide lesser amounts of revenue sharing with the firm.
Information about the mutual funds and share classes that are available through your account, including their
investment policies, restrictions, charges and expenses, is contained in the mutual funds’ prospectuses. You should
read these prospectuses carefully.
Third-Party Payments to Lincoln Investment
Third-Party Payments and Revenue Sharing from Pershing
In our role as introducing broker-dealer for assets held at Pershing, Pershing provides credits, payments and benefits,
including but not limited to fee and expense reductions, that incentivize us to recommend and continue to use
Pershing as clearing firm and custodian and achieve agreed upon asset levels in The Bank of New York Mellon
Corporation (“BNY”)’s affiliated products and services. Pershing and BNY Mellon Advisors, Inc. (“BNYMA”) are
affiliates of BNY.
Pershing Revenue Sharing, Payments and/or Expense Credits with Lincoln Investment. For accounts held
on Pershing’s platform, Pershing provides certain credits and payments to Lincoln Investment, as introducing
broker-dealer, pursuant to a written agreement in consideration of the extension and/or continuation of Lincoln
Investment’s current agreement with Pershing. Lincoln Investment does not refund or offset these
credits/payments against fees paid by clients. This revenue does not vary with respect to the investment
choices/recommendations made in your Pershing account. Overall, the expense credits received by Lincoln
Investment from Pershing for 2025 as allocated to the firm and its affiliates represented less than one percent of
Lincoln Investment’s total advisory revenue, less than one percent of Capital Analysts’ revenue and less than one
percent of Lincoln Investment’s broker-dealer revenue. The receipt of these expense credits and payments create
a conflict of interest to Lincoln Investment to recommend and/or use Pershing as a custodian over other
custodians that do not share these fees, do not provide expense credits/payments to us or that would share lesser
amounts with us. Additionally, under our agreement with Pershing, there is a termination fee schedule with
amounts that decrease over time. Therefore, Lincoln Investment has an incentive to maintain the relationship
with Pershing for a longer period of time. We mitigate these conflicts by disclosing them to you and by not
sharing the credits/payments with your Advisor.
Pershing Margin Participation. For advisory and brokerage accounts held on Pershing’s platform, Lincoln
Investment, as introducing broker-dealer, marks up the base interest rate pursuant to a written agreement with
Pershing, resulting in a higher margin interest rate to you. This mark-up will not exceed 2.25% above the base
interest rate. The receipt of revenue sharing with Pershing creates a conflict of interest to Lincoln Investment to
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use Pershing as custodian over other custodians that do not permit us to mark-up the fees or limit the amount.
Lincoln Investment mitigates this conflict by disclosing it to you and by not sharing it with your Advisor.
Pershing Non-Purpose Loan Markups. For advisory and brokerage accounts held on Pershing’s platform,
Lincoln Investment, as introducing broker-dealer, marks up the base interest rate pursuant to a written agreement
with Pershing, resulting in a higher non-purpose loan interest rate to you. This mark-up will not exceed 0.75%
above the base interest rate. The receipt of revenue sharing with Pershing creates a conflict of interest to Lincoln
Investment to use Pershing as custodian over other custodians that do not permit us to mark-up the fees or limit
the amount. Lincoln Investment mitigates this conflict by disclosing it to you and by not sharing it with your
Advisor.
Trading and Account Service Fees. Lincoln Investment establishes brokerage commission schedules for its
advisory and brokerage accounts. For accounts held on Pershing’s platform for which Lincoln Investment is
introducing broker-dealer (i) Pershing charges trading and account service fees for which Lincoln Investment, as
introducing broker-dealer, has added a mark-up that ranges from 0% to 420%; (ii) For certain trading and
account services for which Pershing does not assess a fee to Lincoln investment, Pershing permits Lincoln
Investment, as introducing broker-dealer, to impose its own fee which is charged to you. The receipt of these
fees creates a conflict of interest for Lincoln Investment since it creates an incentive for Lincoln Investment to
continue to use Pershing as custodian over other custodians that do not permit us to mark-up the trading and
account service fees or would limit the amount, or that would not permit us to set our own fee. We mitigate these
conflicts by disclosing them to you and by not sharing the mark-ups and Lincoln Investment fees with your
Advisor. Your Advisor is permitted to pay certain fees on your behalf in their sole discretion.
Growth Incentive Credits/Payments. For accounts opened and/or assets moved to Pershing by Lincoln
Investment or its affiliate, Capital Analysts, Pershing provides a credit/payment to Lincoln Investment based on
the total asset value of such accounts when the accounts are opened on Pershing, or accounts/assets are moved to
Pershing or retained by Pershing, pursuant to a written agreement with Pershing. The receipt of these
credits/payments creates a conflict of interest to Lincoln Investment and its affiliate, Capital Analysts, to
recommend and/or use Pershing as a custodian over other custodians that do not share these fees, do not provide
credits/payments to us or that would share lesser amounts with us. This revenue is not shared with your Advisor.
Acquisition Financial Support Credits/Payments. For accounts acquired from other firms by Lincoln
Investment or its affiliate, Capital Analysts, Pershing provides a credit/payment to Lincoln Investment based on
the total asset value of such accounts when they will be moved to Pershing or retained by Pershing, pursuant to a
written agreement with Pershing. The credit/payment provided to Lincoln Investment is greater for acquired
accounts that will be moved to Pershing compared to the credit for acquired accounts that will be retained by
Pershing (accounts already existing on Pershing’s platform). The receipt of these credits/payments creates a
conflict of interest to Lincoln Investment and its affiliate, Capital Analysts, to recommend and/or use Pershing as
a custodian over other custodians that do not share these fees, do not provide credits/payments to us or that
would share lesser amounts with us. This revenue is not shared with your Advisor.
The Lincoln Investment Companies Sweep Program. The Lincoln Investment Companies offer a sweep
program (“Sweep Program”) under which uninvested cash or “free credit balances” in your eligible accounts that
are custodied with Pershing are automatically invested or deposited (“swept”) into money market mutual fund(s)
(“Money Fund Sweep Products”), or bank deposit sweep product(s) eligible for FDIC insurance protection up to
$2.5 million (“Bank Deposit Sweep Products”) (collectively referred to as “Sweep Product(s)”), which consist of
interest-bearing bank deposit accounts (“Deposit Accounts”) at Federal Deposit Insurance Corporation (“FDIC”)
member banks. The member banks (“Program Banks”) can include The Bank of New York Mellon (“BNY”) and
BNY Mellon, N.A., banking affiliates of Pershing or other banking affiliates of Pershing. When participating in
the Sweep Program, you appoint Pershing as your authorized agent to establish and maintain Deposit Accounts
at various Program Banks. The Bank Deposit Sweep Products and Money Fund Sweep Products are supported
and operated through a private labelling arrangement with Dreyfus, a division of Mellon Investments
Corporation (“MIC”) and are available only to clients of broker-dealers who clear through Pershing, such as
Lincoln Investment. Pershing has appointed a third-party service provider IntraFi Network LLC (“IntraFi” or
“Administrator”), BNY Mellon Securities Corporation (“BNYSC”) and Dreyfus to provide certain services with
respect to the operation of the Deposit Accounts. MIC is a registered investment adviser and BNYSC is a broker-
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dealer. BNY Mellon Investment Adviser, Inc. (“BNYIA” or “Adviser”) acts as investment adviser for the
Dreyfus Money Fund Sweep Products. Affiliates of BNY include but are not limited to, Pershing, BNYSC, MIC,
BNYIA, and BNY Mellon, N.A. BNY Mellon is the corporate brand for The Bank of New York Mellon
Corporation. For the most up-to-date information, see the applicable product-specific disclosure for a list of
BNY Mellon affiliates and their role in the operation of the Sweep Products.
Depending upon your account type, Lincoln Investment will designate a Sweep Product for use in your account.
Lincoln Investment offers two Bank Deposit Sweep Programs, the Dreyfus Insured Deposits L (“Tiered Rate
Sweep Product”) and the Dreyfus Insured Deposits LV (“Level Fee Sweep Product”), and two Money Fund
Sweep Products, the Dreyfus Government Cash Management Fund Service Shares Sweep Product (Ticker
symbol DGUXX) and the Dreyfus Government Cash Management Fund Investor Shares Sweep Product (Ticker
symbol DGVXX). Each of these Sweep Products except for the Dreyfus Government Cash Management Fund
Investor Shares, offered only to ERISA accounts and as the secondary Sweep Product for balances over
$2,490,000 in the Level Fee Sweep Product, creates financial benefits and conflicts for us as described below.
Lincoln Investment has designated the Dreyfus Government Cash Management Fund Service Shares for non-
ERISA 403(b)7 and 457(b) plans and participant accounts and as the secondary Sweep Product for balances in
excess of $2,490,000 in the Tiered Rate Sweep Product. Lincoln Investment has designated the Tiered Rate
Sweep Product for use in commission-based individual retirement accounts (IRAs) and most non-retirement
brokerage and advisory accounts, and has designated the Level Fee Sweep Product for use in advisory IRAs.
Lincoln Investment receives a portion of the fee paid to Pershing by the Program Banks in connection with the
Bank Deposit Sweep Products and receives distribution assistance payments from Pershing in connection with
the Dreyfus Government Cash Management Fund Service Shares Sweep Product. Accordingly, Lincoln
Investment has a conflict of interest in that we have a financial incentive to designate the Tiered Rate Sweep
Product, the Level Fee Sweep Product and/or the Dreyfus Government Cash Management Fund Service Shares
Sweep Product as the Sweep Product(s) for your account and, for discretionary advisory programs managed by
Lincoln Investment, Lincoln Investment can allocate a portion of assets to the Sweep Product, each of which
generates additional revenue to us. This compensation is a significant source of revenue for Lincoln Investment
and Pershing. Pershing, other financial services firms and third parties could offer the same or similar money
market mutual fund sweep products and/or bank deposit sweep products, at a lower overall cost and higher
return to the investor than is available through the Sweep Program, whether directly through the provider or
through a sweep program offered by a different financial services firm. This receipt of revenue sharing from
Pershing creates a conflict of interest to Lincoln Investment to use Pershing as a custodian over other custodians
that do not share these fees, do not share these payments or that would share lesser amounts or that would not
permit us to set our own fee, to offer the Sweep Products and to recommend that you utilize the Sweep Products.
Lincoln Investment receives a greater financial benefit when cash is swept into the above Bank Deposit Sweep
Products and Money Fund Sweep Product than it otherwise would if your cash balance is held elsewhere, and
any compensation the firm receives reduces the interest and/or dividend you receive, and your overall investment
return. This compensation is retained by the firm and is not shared with you. Lincoln Investment receives greater
compensation as assets and/or accounts utilizing the Sweep Products increase, as more fully described below.
The Sweep Product fees that we receive are in addition to any investment advisory fees that you pay to Lincoln
Investment and your Advisor. This means that Lincoln Investment earns two layers of fees on the same Sweep
Product balances in your account, which can result in you experiencing a negative overall investment return. We
also receive different fees based on the Sweep Product designated for your account. Therefore, we have an
incentive for you to use (and invest your assets in) the sweep products that increase our compensation. If you
desire to maintain a cash balance in your account for an extended period of time awaiting investment and/or seek
the highest yields currently available in the market for your cash balance, please contact your Advisor or Lincoln
Investment for options outside of the Sweep Products. In order to mitigate these conflicts, Lincoln Investment
does not share this revenue with your Advisor. Your Advisor has the ability to waive the advisory fee on all
Sweep Products, should you request it.
Lincoln Investment has designated the Tiered Rate Sweep Product for use in commission-based IRAs and most
non-retirement brokerage and advisory accounts, and has designated the Level Fee Sweep Product for use in
advisory IRAs. Bank Deposit Sweep Products are an important source of significant revenue for Lincoln
Investment, Pershing, and Pershing’s affiliated Program Banks that participate in the Sweep Program. For
additional information regarding Pershing’s and their affiliates’ conflicts of interest, please see the link to our
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Disclosures web page, included below. Lincoln Investment receives a portion of the fee paid to Pershing by the
Program Banks. Lincoln Investment sets the amount of the fee it receives from Pershing on your Bank Deposit
Sweep Product accounts and/or assets. This is a conflict of interest as it permits Lincoln Investment to assess a
higher fee to you in order to increase our revenue. Pershing offers other sweep products for which no
remuneration or less remuneration would be paid to Lincoln Investment, as introducing broker-dealer. The
portion of the fee received by us on the Bank Deposit Sweep Products is greater than the yield that you will
receive. Amounts paid to Lincoln Investment, Pershing and the Administrator reduce the interest rate paid on
your Bank Deposit Sweep Product balance. Therefore, the higher the compensation paid to us, the lower the
interest paid to you; the lower the compensation paid to us, the higher the interest paid to you. You should
understand that this can result in you experiencing a negative overall investment return with respect to your
balance in the Bank Deposit Sweep Product. Additionally, bank deposit sweep products typically yield lower
returns than money market mutual funds. However, because Lincoln Investment earns a higher fee when you
invest in Bank Deposit Sweep Products than if you invest in other money market products such as money market
mutual funds, within or outside of the Sweep Program, Lincoln Investment is incentivized to designate Bank
Deposit Sweep Products for your account(s). Lincoln Investment receives greater compensation related to Bank
Deposit Sweep Products as the amount of assets and/or accounts utilizing the Sweep Products increase and can
take up to 6.00% of the interest rate paid on the balances of your Deposit Accounts. For additional information
on Lincoln Investment’s current fees and compensation earned in relation to the Sweep Program, see the link to
our Disclosures web page, included below. Accordingly, these arrangements present a conflict of interest to
Lincoln Investment because they provide an incentive for us to offer the Bank Deposit Sweep Products as our
default sweep products, to maintain balances in the Bank Deposit Sweep Products over other investment options,
including money market mutual funds, and for us and your Advisor to recommend that you enroll in and utilize
the Bank Deposit Sweep Products. For Bank Deposit Sweep Products balances in excess of $2,490,000, Lincoln
Investment has designated a secondary Money Market Sweep Product. For the Tiered Rate Sweep Product, the
secondary Money Market Sweep Product is Dreyfus Government Cash Management Fund Service Shares
(Ticker symbol DGUXX). If your excess balance is swept into Dreyfus Government Cash Management Fund
Service Shares, Lincoln Investment will earn fees on that balance, as further discussed below. For the Level Fee
Sweep Product, the secondary Money Market Sweep Product is Dreyfus Government Cash Management Fund
Investor Shares (Ticker symbol DGVXX). For additional information regarding these secondary Sweep
Products, please see the link to our Disclosures web page, included below. Program Banks do not have a duty to
offer the highest rates available or rates that are comparable to money market mutual funds or those offered by
other depository institutions or deposits held at Program Banks outside of the Sweep Program. The receipt of
revenue sharing from Pershing and the ability for Lincoln Investment to set its fee for the Sweep Products
creates a conflict of interest for Lincoln Investment to use Pershing as a custodian and to offer the Bank Deposit
Sweep Products we make available to you over other custodians or sweep products that do not pay a portion of
their fees to us (share revenue), share lesser amounts, or that do not permit the introducing broker-dealer to set
the fee it will assess for the Sweep Products.
Lincoln Investment has designated the Dreyfus Government Cash Management Fund Service Shares for non-
ERISA 403(b)7 and 457(b) plans and participant accounts and as the secondary Sweep Product for balances in
excess of $2,490,000 in the Tiered Rate Sweep Product, and Dreyfus Government Cash Management Fund
Investor Shares Sweep Product for ERISA accounts and as the secondary Sweep Product for balances in excess
of $2,490,000 in the Level Fee Sweep Product.
A Money Fund Sweep Product earns dividends, interest and other income from its investment, and distributes
this income (less expenses) to shareholders as dividends. For the Dreyfus Government Cash Management Fund
Service Shares Sweep Product, Lincoln Investment utilizes a share class that provides remuneration to us
(distribution assistance) which reduces the dividend you receive, even though other share classes are available to
Lincoln Investment that would pay Lincoln Investment less and you more. Lincoln Investment receives
distribution assistance from Pershing in the form of annual compensation of up to 0.55% for assets in the
Dreyfus Government Cash Management Fund Service Shares Sweep Product. This is not the least expensive
share class of the Dreyfus Government Cash Management Fund available or the least expensive share class
available through Pershing. Lincoln Investment utilizes a higher expense share class over other less expensive
share classes that would otherwise be available and of lower cost to you. There are less expensive share classes
of the same money market mutual fund available that would not provide revenue sharing with Lincoln
Investment or would provide lesser amounts of revenue sharing to us. Share classes with higher expenses can
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lower your returns over time. This receipt of revenue sharing from Pershing creates a conflict of interest to
Lincoln Investment to use Pershing as a custodian and share classes offered by Pershing that provide
remuneration over other custodians and share classes that do not share these fees or payments, or that would
share lesser amounts, to offer the Sweep Products and to recommend that you utilize and maintain a greater
balance in the Sweep Products. Pershing offers other sweep products for which no remuneration or less
remuneration would be paid to Lincoln Investment, as introducing broker-dealer. The investment adviser to
Dreyfus Government Cash Management Fund Services Shares is BNYIA. BNYIA has engaged its affiliate,
Dreyfus, a division of Mellon Investments Corporation, to serve as the sub-investment adviser for Dreyfus
Government Cash Management Fund Services Shares. Lincoln Investment has an incentive to offer/recommend
Dreyfus Government Cash Management Fund Services Shares due to its agreement with Pershing which
incentivizes us to offer Pershing or its affiliates’ products so that we may share in a portion of the revenue.
The Dreyfus Government Cash Management Fund Investor Shares Sweep Product, for which no distribution
assistance is received by Lincoln Investment, is available only to ERISA accounts and as the secondary Sweep
Product for balances in excess of $2,490,000 in the Level Fee Sweep Product.
As previously indicated, certain Program Banks as well as Sweep Products affiliated with Pershing are made
available within the Sweep Program. Due to Lincoln Investment’s custodial and clearing arrangement with
Pershing, this creates a conflict of interest for Lincoln Investment because it provides an incentive for us to offer
a Sweep Product and to recommend utilizing the Sweep Product so that Pershing receives additional
compensation and shares it with us.
For additional information and clarity regarding all Sweep Products offered including the designated Sweep
Product and secondary Sweep Product for your account, eligibility criteria, as well as applicable fees, rates, bank
lists, and conflicts of interest, please carefully review our Sweep Program disclosures, available on our public
website under our Disclosures section or at https://www.lincolninvestment.com/Disclosures. Please refer to The
Lincoln Investment Companies Sweep Program General Terms and Conditions to access the applicable money
market mutual fund prospectus.
In aggregate, the third-party payments and revenue sharing from Pershing to Lincoln Investment attributable to
Lincoln Investment advisory accounts in 2025 described above represented approximately seven percent of Lincoln
Investment’s total advisory revenue in 2025. The receipt of these third-party payments and expense credits create a
conflict of interest to Lincoln Investment to use Pershing as a custodian over other custodians that do not share these
fees, do not provide expense credits or that would share lesser amounts. Lincoln Investment mitigates these conflicts
by disclosing them to you and not sharing these payments/credits with your Advisor.
Other Conflicts and Potential Conflicts Related to Our Relationship to Pershing and its Affiliates
Pursuant to a written agreement, Lincoln Investment is obligated to provide certain providers/custodians, such as
Pershing and its affiliates, including BNYMA, the opportunity to participate in Lincoln Investment’s conferences or
events, without the separate payment of sponsor or registration fees. The ability to participate in such events
provides Pershing, BNYMA and its affiliates the opportunity to promote their affiliated products and services to
Lincoln Investment, its affiliate Capital Analysts and our Advisors. Increased use of BNY affiliated products and
services by Advisors of the firm will benefit the firm by assisting us with meeting the asset levels required for us to
receive a reduction/waiver in certain Pershing/BNYMA expenses. Platforms/custodians, including
Pershing/BNYMA, can waive or negotiate their respective fees assessed to you, Lincoln Investment and/or its
affiliates, and/or your Advisor, in each platform/custodian's sole discretion. Lincoln Investment and/or its affiliates
are not required to pass the waiver/reduction in cost along to you. We recognize these as conflicts for Lincoln
Investment and its affiliate, Capital Analysts, and mitigate these conflicts by disclosing them to you.
Sales & Marketing Support Revenue
Lincoln Investment receives Sales and Marketing Support as described below and includes Flat Fee Sponsors, Other
Sales Support and Asset and Sales Based Sponsors (collectively, “Sales and Marketing Support”). In order to
minimize the conflicts associated with the receipt of these fees, Lincoln Investment does not receive Flat Fee
Sponsor and Other Sales Support payments that are based on the amount of advisory account assets or advisory
account transactions with a particular sponsor, or that are based on ERISA advisory account assets. However, Flat
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Fee and Other Sales Support Sponsors can compensate Lincoln Investment from assets of the mutual fund, the
fund’s investment adviser, distributor or other fund affiliate’s assets. While payments out of the fund's investment
adviser, distributor or other fund affiliate's revenues or profits are not directly paid from the fund's assets, fund
affiliate revenues or profits can, in part, be derived from fees earned for services provided to and paid for by the
fund. Payments out of fund assets can lower investor returns and performance over time. Lincoln Investment can
also receive Shareholder Services Fees from the same fund families and investment advisers that provide Sales and
Marketing Support. These sources of payments are a conflict of interest to Lincoln Investment to recommend and
promote those funds, fund families, investment advisers, distributors or other fund affiliates over others that do not
provide Sales and Marketing Support or that provide lower amounts of Sales and Marketing Support.
Flat Fee Sponsors. Lincoln Investment has partnered with a select group of third-party money managers and
product sponsors who pay to assist Lincoln Investment in the training and education of and outreach to Lincoln
Investment’s Advisors, at Lincoln Investment sponsored events, on such topics as advisory products and
services, practice management, tools and technology, consumer education, and policies, rules and regulations.
Additional opportunities can include but are not limited to attendance at and support of recognition club events,
exhibit booths, advisor presentations, seminars, mailings and publications. These sponsors provide financial
support to Lincoln Investment in the form of a flat-dollar amount that may be amended annually and is not based
on the sales of their proprietary products or services. Sponsors can compensate us from fund assets, the fund’s
investment adviser, distributor or other affiliate’s assets. Payments made out of fund assets can lower investor
returns and performance over time. Advisors do not share in any portion of these payments so as to mitigate any
conflict for an Advisor to recommend one product or money manager over another. This financial support allows
Lincoln Investment to defray or offset costs associated with Lincoln Investment sponsored events and other
educational and outreach tools and services. The financial support by these Sponsors to Lincoln Investment
presents a conflict of interest.
All Flat Fee Sponsors do not pay Lincoln Investment the same amount, and depending on the amount of the
payment from the Flat Fee Sponsor, the access to Lincoln Investment sponsored events can differ. For example,
Lincoln Investment holds a number of sales conferences both nationally and regionally throughout the year to
educate advisors. The higher the annual flat fee payment, the more events the Flat Fee Sponsor will be invited to
attend. Flat Fee Sponsors have more opportunities than other product sponsors and money managers that are not
Flat Fee Sponsors to market to and educate Advisors, which could pose a conflict to Advisors to offer these
sponsors’ products or services over others. Advisors do not share in any portion of these payments so as to
mitigate any such conflict.
In 2025, the financial support from Flat Fee Sponsors paid to Lincoln Investment, as allocated across all
investment advisory assets with Lincoln Investment Planning, LLC and its affiliate, Capital Analysts, LLC did
not exceed one percent of total revenue for either of the affiliated registered investment advisers and in aggregate
was less than one percent of the combined revenue for both affiliated registered investment advisers. We do not
believe that these revenues are material. In 2025, Flat Fee Sponsors who compensated Lincoln Investment with a
flat fee payment, and offer a fund or advisory program that could be used in your advisory account, in order from
highest to lowest payment were Russell Investments, Clark Capital Management, AAMA, American Funds,
PIMCO Funds, Meeder Funds, Security Benefit Life, Nationwide, Transamerica Life, Federated Investors, BNY
Mellon, and Doubleline.
Some of the Flat Fee Sponsor revenue is used by Lincoln Investment to support the ongoing operational
expenses of Lincoln Investment, and its affiliates, and not used solely for sales and marketing support.
Other Sales Support. From time to time, product sponsors and third-party money managers assist Advisors in
their sales and marketing efforts by subsidizing certain Advisor costs, such as client meetings or workshops,
mailings, administrative expenses and technology support. The amount received from any one product sponsor
or third-party money manager in 2025 did not exceed $35,000. The sales support presents a conflict of interest in
that it could incentivize an Advisor to offer one product or money manager over another that does not provide
these subsidies or provides lesser amounts. To mitigate the conflict of interest presented by these payments and
subsidies, the amount is approved by Lincoln Investment and is monitored to ensure that it is not too frequent or
excessive. Also, Advisors are invited from time-to-time by product sponsors to due diligence and educational
meetings or seminars hosted by the product sponsor or money manager. This presents a conflict of interest that
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could incentivize an Advisor to offer one product or money manager over another that does not offer these
meetings or seminars. Lincoln Investment must grant permission to our Advisors to attend any meeting or
seminar hosted by a product or advisory service sponsor. Lincoln Investment approves events that are limited to
education or due diligence only and allows the product sponsor to provide meals, hotel accommodations and
reimbursement to the Advisor, through Lincoln Investment, for travel expenses only. The education of our
Advisors in the offerings that are available to them is a key component of providing prudent investment advice
to you.
Ancillary Sales & Marketing Support Revenue paid to Lincoln Investment that is not tied to your Advisory
assets, or the platform where your Advisory assets are held, but is tied to the Non-Advisory assets or
transactions in which you may invest
Asset and Sales Based Sponsors. In connection with non-investment advisory (non-fee-based) assets of our
investors, and in addition to the compensation described above, Lincoln Investment receives Sales and
Marketing support from product sponsors, mutual fund companies, insurance companies and other third-party
providers to assist in the marketing and sales efforts of employees and Advisors (“Asset and Sales Based
Sponsors”). Asset and Sales Based Sponsors have the opportunity to educate and train employees and Advisors
with respect to investment products and services, practice management, tools and technology, consumer
education, and policies, rules and regulations. Additional opportunities can include but are not limited to
attendance at and support of recognition club events, exhibit booths, advisor presentations, seminars, mailings
and publications. The support provided by these sponsors is based on brokerage-only (non-investment advisory)
assets and brokerage transactions and not based on your advisory account assets or ERISA advisory assets. We
receive compensation from these sponsors in various forms, including as a flat fee, a percentage of the amount of
brokerage assets held by investors, a percentage of sales, or any combination of these methods. The amounts of
these payments can vary by the type of product and by provider and can include, but are not limited to,
distribution fees and shareholder service fees. All Asset and Sales Based Sponsors do not pay Lincoln
Investment the same amount, and depending on the amount of the payment, the access to Lincoln Investment
sponsored events and other opportunities can differ. The higher the payment, the greater the access for the Asset
and Sales Based Sponsor to attend events, participate in marketing and sales opportunities and interact with
Advisors. This presents a conflict of interest to Advisors to offer these sponsors’ products or services over
others. Advisors do not share in any portion of these payments so as to mitigate any such conflict. Additionally,
some Asset and Sales Based Sponsors make a monthly or quarterly payment or additional monthly or quarterly
payment based on the assets you hold in a fund or variable insurance product over a period of time. As you may
have both a brokerage account and an advisory account with us, we want you to understand that Lincoln
Investment will receive Sales and Marketing Support based on assets or sales in connection with your brokerage
account assets and transactions. The Asset and Sales Based Sponsors payments present a conflict of interest to
Lincoln Investment to recommend Asset and Sales Based Sponsors that provide sales and marketing support
over others that do not or that provide lesser amounts. Some of the Asset and Sales Based Sponsor revenue is
used by Lincoln Investment to support the ongoing operational expenses of Lincoln Investment, and its affiliates,
and not used solely for sales and marketing support.
The following is a list of Asset and Sales Based Sponsors in order of high to low total compensation paid to
Lincoln Investment as broker-dealer based on non-fee based account assets or sales in 2025: Security Benefit
Life, Franklin Templeton Group, Jackson National Life Ins Co, Allianz, Lincoln National Life, Athene,
Nationwide, AXA Equitable Life Insurance Company, Prudential, Brighthouse Financial, Pacific Life,
Transamerica Life, Mewbourne Development Corporation, Simplicity, the Standard, Pershing, Blue Rock
Capital, Voya Mutual Funds, and Meeder Funds. The Asset and Sales based Compensation in 2025 was less than
$3 million dollars from these product sponsors and represented less than one percent of the total revenues of
Lincoln Investment. We are disclosing this information to you as certain providers and products offered by the
providers shown above could be available within our investment advisory offerings.
Outside of the Sweep Program, Pershing, as clearing firm for accounts introduced by Lincoln Investment, shares
with Lincoln Investment a nominal amount of asset-based revenue it receives from certain mutual fund
companies in non-advisory accounts. As this revenue received from Pershing is non-advisory related and not
material, Lincoln Investment is disclosing the conflict that we receive this revenue rather than list each mutual
fund product that generated the compensation to the firm.
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Other Conflicts and Potential Conflicts
Loans, Advances and Other Benefits. Lincoln Investment can extend loans, provide bonuses and other
benefits, provide commission/fee advances, and pay for practice management services for an Advisor to assist
the Advisor in transitioning to the firm, and/or maintaining or expanding his or her business. Lincoln Investment
does not verify that any payments made are used for these purposes. Sometimes the availability and amount of
loans and advances are conditioned upon, are forgiven (waived) or reduced, in whole or in part, interest rates
reduced, and/or bonuses provided if an Advisor remains affiliated with the firm or achieves certain sales or
assets under management thresholds, revenue targets, production levels, asset additions, new client goals, client
retention goals, recruiting goals and certain practice management goals or conditions, individually or with other
Advisors. These practices present a conflict of interest in that the Advisor has a financial incentive to affiliate
with and remain affiliated with the firm during the repayment period in order to receive these benefits over other
firms that do not offer these incentives or offer a similar level of incentives. These practices also present a
conflict in that the Advisor has a financial incentive to generate more business or to recruit other financial
professionals to generate more business, and achieve certain sales, revenue, asset additions or asset management
thresholds in order to receive a loan or advance, increase the amount of the loan or advance, and/or satisfy or
reduce the amount of the loans or advances. The extent of the conflict can increase as your Advisor approaches
certain milestones. In situations where a sales, production, recruiting, revenue, asset additions, assets under
management threshold or other financial contingency exists, this conflict of interest will be disclosed in your
Advisor’s Form ADV 2B Supplement (“BIO Brochure”), which is required to be delivered by the Advisor to
every client. Lincoln Investment mitigates these conflicts by disclosing them to you and supervising the
investment advisory activities and brokerage practices of its Advisors.
Additionally, Lincoln Investment can extend a loan or advance to an Advisor for which repayment is required
which can create a conflict for the Advisor to generate more business in order to repay the loans or advances to
the firm during the repayment period. Additionally, some Advisors receive benefits as they transition to the firm
and/or for maintaining their business, which can include but is not limited to, technology services, administrative
support, licensing, insurance and administrative fees, the opportunity to participate in a unit appreciation rights
plan of an affiliate or parent of Lincoln Investment, and reimbursement of fees associated with transitioning
accounts. These practices present a conflict of interest in that the Advisor has a financial incentive to affiliate
with and remain affiliated with the firm over other firms that do not offer these incentives or offer a similar level
of incentives. Lincoln Investment mitigates these conflicts by disclosing them to you and supervising the
investment advisory activities and brokerage practices of its Advisors.
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Item 3: Table of Contents
Item 1: Cover Page ....................................................................................................................................... 1
Item 2: Material Changes ............................................................................................................................. 2
Item 3: Table of Contents ............................................................................................................................ 12
Item 4: Advisory Business ........................................................................................................................... 13
Item 5: Fees and Compensation.................................................................................................................. 22
Item 6: Performance-Based Fees and Side-by-Side Management .............................................................. 42
Item 7: Types of Clients .............................................................................................................................. 42
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 42
Item 9: Disciplinary Information ................................................................................................................ 47
Item 10: Other Financial Industry Activities and Affiliations .................................................................... 48
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............. 49
Item 12: Brokerage Practices ..................................................................................................................... 49
Item 13: Review of Accounts ....................................................................................................................... 51
Item 14: Client Referrals and Other Compensation ................................................................................... 52
Item 15: Custody ......................................................................................................................................... 52
Item 16: Investment Discretion ................................................................................................................... 53
Item 17: Voting Client Securities ................................................................................................................ 53
Brochure Supplement(s) Included:
• Lincoln Investment Wrap Fee Program Brochure (Form ADV Part 2A Appendix I)
•
Investment Management & Research Team Brochure Supplement (Form ADV Part 2B)
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Item 4: Advisory Business
This section describes our firm, the advisory services we offer, how we tailor your portfolio to your individual
needs, which of our advisory services allows you to impose investment restrictions and the total amount of assets we
manage.
Our Firm
Who we are… Based in the suburbs of Philadelphia, Lincoln Investment Planning, LLC (“Lincoln” or “Lincoln
Investment”) was established in 1968 with a focus on the retirement planning needs of educators and employees of
non-profit organizations utilizing 403(b) and 457 retirement plans. Lincoln Investment was registered with the SEC
as an investment adviser in 1978. Over the years, we have expanded our range of investment advisory services to
include individual retirement accounts (“IRAs”), ERISA plans and the non-retirement investment and insurance
needs of our clients and their businesses.
Lincoln Investment is both a broker-dealer and a SEC registered investment adviser with a network of registered
representatives and investment adviser representatives (“Advisors”) located throughout the United States. Most
Advisors are not employees of Lincoln Investment; but independent contractors, contracted to offer and perform the
services of Lincoln Investment.
Lincoln Investment is wholly-owned by Lincoln Investment Capital Holdings, LLC, a Delaware limited liability
company. Lincoln Investment is under common ownership and control with Capital Analysts, LLC, a SEC
registered investment adviser. Advisors may be dually registered with one or both of these investment advisers and
can offer their services. Advisory offerings and pricing vary among the registered investment advisers. We refer to
these companies jointly as The Lincoln Investment Companies.
Our Advisory Services
What we offer… Lincoln Investment offers the following investment advisory services. A more detailed description
of each service is provided under the corresponding headings below, as well as in Item 5: Fees and Compensation.
I. Your Financial Advisor’s Services: Advisor Consulting, Client Custom Portfolios and Advisor
Managed Model Portfolios
II. Lincoln Investment Asset Management Programs: Model Portfolios Managed by Lincoln Investment
III. Third-Party Managed Model and Third-Party Custom Portfolios
IV. Periodic Investment Consulting
V. Financial Planning Services
VI. ERISA Retirement Plan Advice
In choosing one or more of the services above, your Advisor will work with you to assess your needs and investment
objectives. You will be asked to complete a confidential investor profile, or a similar questionnaire or application,
providing personal and financial information to assist in this assessment. Your Advisor will collect information
including, but not limited to, your investment goals, income requirements, time horizon and tolerance for risk in
order to tailor his or her recommendations to your needs and objectives. Our goal is to provide you with the most
appropriate investment advisory service or services to help you meet your financial goals.
Our Fiduciary Role… Lincoln Investment and your Advisor assume a fiduciary duty to provide you with
investment recommendations that are in your best interest. This fiduciary duty extends to all advisory accounts that
you maintain with us, but such fiduciary duty does not extend to brokerage or other non-advisory accounts or
investments. The level of monitoring in your advisory account will depend on the advisory program you select, your
advisory agreement with us and your Advisor. If Lincoln Investment or your Advisor have been granted full
discretionary trading authority over your advisory account assets, Lincoln Investment or your Advisor will provide
ongoing monitoring and will make changes in your account as deemed necessary. For all other advisory accounts,
you and your Advisor will review your advisory account’s objectives, investments and performance relative to your
objectives and financial situation at least annually to allow your Advisor the opportunity to recommend changing or
maintaining the objectives or investments in your account. See your investment advisory agreement for the level of
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discretion and monitoring granted to Lincoln Investment or your Advisor, which can vary based on the advisory
program you select.
Investment Advice Provided to Certain Retirement and Tax-Advantaged Accounts
When we and/or your Advisor provide investment advice to you regarding your Covered Retirement Plans, Lincoln
Investment and your Advisor are fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act of 1974, as amended (“ERISA”) and/or the Internal Revenue Code (“IRC”), 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 and your Advisor to act in your best interest and not put our interests
ahead of yours. Under this special rule’s provisions, we and your Advisor must: meet a professional standard of care
when making investment recommendations (give prudent advice); not place 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 reasonably 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. Covered Retirement Plans include the following account types: Individual Retirement Account (“IRA”);
Individual Retirement Annuity; Roth IRA, Beneficiary IRA, Beneficiary Roth IRA; SEP-IRA, SARSEP, SIMPLE
IRA; One-Participant 401(k); Health Savings Account; Archer Medical Savings Account; Coverdell Education
Savings Account; and Accounts held by ERISA Title I Plan participants/beneficiaries with authority to direct the
distribution of assets from their account. When we provide investment advice to your Covered Retirement Plan as
described in this paragraph, we will disclose to you the types of services to be provided and material facts relating to
conflicts of interest that are associated with the recommendations made to you. These disclosures are provided to
you in various documents, including The Lincoln Investment Companies Investor Agreement and Disclosure
Handbook, Lincoln Investment’s Form CRS and its affiliated investment adviser, Capital Analysts’ Form CRS, your
Advisor’s BIO Brochure (Form ADV Part 2B), account applications, prospectuses and specific platform or program
disclosure documents and the Investment Advisory Disclosure Brochure of Lincoln Investment (Form ADV Part 2A
and Wrap Fee Program Brochure).
Lincoln Investment and your Advisor offer advisory services on a number of different platforms and custodians.
Available platforms or custodians can differ depending upon the tax type of your account(s), your employer if you
are a participant in an employer plan, the investment types you choose, the account custodian you wish to work
with, the advisory programs you prefer and the pricing you wish to pay.
Lincoln Investment offers both non-Wrap Fee Programs and Wrap Fee Programs. A Wrap Fee Program is an
investment advisory program in which you pay one bundled fee to compensate Lincoln Investment and your
Advisor for their services and to pay the transaction and clearing costs associated with transactions in your advisory
account. The Lincoln Investment Wrap Fee Programs are detailed in the Lincoln Investment Wrap Fee Program
Brochure (Form ADV Part 2A Appendix I) attached. You should only choose a Wrap Fee Program if you or your
Advisor expect to trade regularly in the account. A non-Wrap Fee Program is an investment advisory program in
which you pay an unbundled fee to compensate Lincoln Investment and your Advisor for their services as well as
transaction and clearing costs associated with your advisory account as described in this brochure.
I. Your Financial Advisor’s Services: Advisor Consulting, Client Custom Portfolios and Advisor Managed
Model Portfolios
Your Advisor’s role is to earn and maintain a relationship with you to provide you financial and life planning
consultation, as needed by you, as well as investment advice services which include assisting you in the
determination of the appropriate advisory investments and programs for you and conversing with you on an as-
needed or as requested basis to ensure that the investments and programs continue to meet your stated objectives
and needs. Some advisors may also provide supplemental reports on a periodic basis to assist you in evaluating
the effectiveness of the investments and advisory program(s). Advisors may provide periodic non-discretionary
or limited discretionary investment advice to their clients, and certain approved Advisors may provide ongoing
discretionary management to their clients. Either way, your Advisor has the responsibility to make
recommendations or select securities based on your needs and objectives. All advice is geared to meet your risk
tolerance, income, any investment restrictions and tax management objectives, if applicable. See your investment
advisory agreement for the level of discretion and monitoring granted to Lincoln Investment or your Advisor,
which can vary based on the advisory program you select.
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Advisors provide periodic non-discretionary advice to their clients in fee-based Advisor Managed Model
Portfolios and Client Custom Portfolios, unless an Advisor has been granted the authority to manage the account
on a discretionary basis. For those Advisors who have been granted the authority to manage accounts on a
discretionary basis, discretionary authority may be exercised within Advisor Managed Model Portfolios, where
your account is managed to the stated objectives of the model portfolio, or Client Custom Portfolios, a custom
advisor managed portfolio constructed and managed to meet your specific objectives. Discretionary authority
means your Advisor has the authority to decide on the securities to purchase, sell or trade in your account
without prior consultation with you. With regards to the Client Custom Portfolios Program offered on the
Lincoln Signature Solutions platform custodied at Pershing LLC (“Pershing”), your Advisor has the authority to
act with “Limited Discretion.” Limited Discretion includes the authority to rebalance your account to a portfolio
allocation preauthorized by you, liquidate account assets to replenish the established sweep position or free
credit balance, and reallocate assets from your sweep position or free credit balance to an existing cash
equivalent investment if the balance in the Sweep Position or free credit balance has increased from the agreed
upon target allocation or if the anticipated debit balance has changed. Your investment advisory agreement will
identify whether and to what extent you have granted your Advisor discretionary authority on your account, as
well as the specific authorities granted to your Advisor.
Each Advisor follows his or her own investment discipline and may or may not establish a minimum investment
amount. The fees charged by Advisors for Advisor Managed Model or Client Custom Portfolios will vary
depending on the consultation services, platform utilized and the individual Advisor’s fees and services. Some
Advisors manage or advise mutual fund-only portfolios, while others manage or advise portfolios containing
stocks, exchange-traded funds (“ETFs”), exchange-traded notes (“ETNs”), bonds, and/or options. Consult with
your Advisor to learn more about the advisory services and fees he or she offers. Your Advisor’s education,
licenses and professional designations are described in Form ADV Part 2B Brochure Supplement (“Form ADV
Part 2B Brochure Supplement” or “Financial Professional BIO Brochure”), a copy of which your Advisor will
provide to you.
Lincoln Signature Solutions – Client Custom Portfolios Program
Lincoln Investment makes available an investment advisory platform custodied at Pershing referred to as
“Lincoln Signature Solutions.” The Lincoln Signature Solutions platform offers two (2) main product lines:
Lincoln Workplace Retirement Solutions for non-ERISA 403(b) and 457(b) employer retirement plans and
Lincoln Wealth Solutions for most other investors whose assets are custodied at Pershing. Below is a description
of the Client Custom Portfolios offering on the Lincoln Signature Solutions platform. For Wrap Fee Programs
offered on the Lincoln Signature Solutions platform on Pershing or other third-party custodians, see Lincoln
Investment’s Form ADV Part 2A Appendix I (Wrap Fee Brochure).
Lincoln Investment sponsors and currently offers the Client Custom Portfolios Program on the Lincoln Signature
Solutions platform. In the Client Custom Portfolios Program, you appoint your Advisor to provide investment
advice to you regarding mutual funds, ETFs, options, unit investment trusts (“UITs”), equity and fixed income
securities, alternative assets such as business development companies (“BDCs”) and limited partnerships (or for
403(b)/457(b) accounts, mutual funds and exchange-traded funds that are regulated investment companies
(“RICs”) under Section 851(a) of the IRC and are eligible 403(b) investments), and grant your Advisor Limited
Discretion. You will make the ultimate decision regarding the purchase, sale, allocation or reallocation of your
Assets.
Advisor Managed Model Portfolio and Client Custom Portfolio Offerings
Custodian of Assets
Advisory
Offering
Discretionary
Program
Minimum
Investment
Investment
Types
No
Mutual funds
Depends on
platform and
individual
Advisor
Matrix Trust Company;
Pentegra Trust
Company; Security
Benefit
Advisor Managed
Program (Model
Portfolios and/or
Client Custom
Portfolios)
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Advisor Managed Model Portfolio and Client Custom Portfolio Offerings
Custodian of Assets
Advisory
Offering
Discretionary
Program
Minimum
Investment
Investment
Types
Depends on
platform and
individual
Advisor
Advisor Managed
Program (Model
Portfolios and/or
Client Custom
Portfolios)
General
Securities
such as, but
not limited to,
mutual funds,
stocks, bonds,
ETFs, ETNs,
and options
Varies - Your
Advisor can act
with discretionary
authority, but only
if he or she has
been (1) approved
by Lincoln
Investment for
discretion; and
(2) authorized in
writing by you.
Charles Schwab & Co.,
Inc.;
National Financial
Services/Fidelity
Brokerage Services,
LLC¹; Fidelity
Investments
Institutional Operations
Company; Nationwide;
Prudential;
SEI Private Trust
Company
Pershing LLC
Depends on the
individual
Advisor
Client Custom
Portfolios
Program on
Lincoln Signature
Solutions
General
Securities
such as, but
not limited to,
mutual funds,
stocks, bonds,
ETFs, ETNs,
and options
Varies - Your
Advisor acts with
Limited Discretion,
unless they have
been approved for
full discretionary
authority by (1)
obtaining approval
from Lincoln
Investment for
discretion; and
(2) becoming
authorized in
writing by you.
¹Certain Advisors have been pre-approved to use 55I, LLC (“55ip”) for trading and tax management overlay services.
II. Lincoln Investment Asset Management Programs: Model Portfolios Managed by Lincoln Investment
Lincoln Investment offers a number of in-house managed asset management programs comprised primarily of
mutual funds and ETFs on Pershing’s platform (“Premier Asset Management Programs”) and other custodial
platforms as shown in the table below. Premier Asset Management Programs offered on Pershing are wrap fee
programs. See Lincoln Investment’s Wrap Fee Brochure for more information. Lincoln Investment manages
variable annuity sub-accounts; however, the variable annuity programs are closed to new investors and
contributions. These programs are managed to meet the stated objective of the portfolio, thus the term “Model
Portfolio.” When you choose a Lincoln Investment Asset Management Program Model Portfolio, you will
authorize Lincoln Investment to make discretionary asset allocation decisions in your account based on the
discipline and risk level of the Model Portfolio chosen. Lincoln Investment has engaged third-party asset
managers to provide Lincoln Investment with Model Portfolios in alignment with each model’s stated
discipline and risk level (“Sub-Advisers”). Each Sub-Adviser appointed by Lincoln Investment offers various
disciplines of investing. Based on information provided by you, your Advisor will make a recommendation to
you as to the appropriate Asset Management Program and risk level for you. Although the management
authorization of your account remains with Lincoln Investment, Lincoln Investment relies on the expertise and
management disciplines of its Sub-Advisers, when they are engaged, to provide Model Portfolios that align to
each model’s stated discipline and risk level. Lincoln Investment, however, retains the authority to change
Sub-Advisers at any time. If a Sub-Adviser or Model Portfolio ceases to be available or is removed from
Lincoln Investment's offerings, Lincoln Investment will notify you in writing and indicate, if appropriate, an
alternative Asset Management Program.
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Lincoln Investment Managed Model Portfolio Offerings
Discipline
Advisory Offering
Investment Types
Custodian of Assets
Strategic
Lincoln Strategic
Minimum
Investment
$10,000
Mutual funds
Strategic
Mutual funds
Progressive Asset
Management²
$150/
$10,000³
Dynamic
Adaptive Intelligence
Models (AIM) Active
$150/
$10,000³
Fidelity Investments
Institutional Operations
Company1
Charles Schwab & Co.,
Inc.;
TIAA1
Charles Schwab & Co.,
Inc.;
Dynamic
Adaptive Intelligence
Models (AIM) Index
$150/
$10,000³
Charles Schwab & Co.,
Inc.;
Dynamic
N/A4
Adaptive Intelligence
Models (AIM)
Fidelity Investments
Institutional Operations
Company1;
TIAA1
Mutual funds
(primarily actively
managed funds, but
passive managed
funds can also be
utilized)
Index funds,
(primarily passive
managed funds, but
active managed funds
can also be utilized)
Varies based on Plan
Sponsor; Mutual
funds or index mutual
funds may be used,
passive and active
1 Mutual funds utilized will vary based on the restrictions imposed by the employer retirement plan sponsor, where applicable.
² The Progressive Asset Management Program adds additional diversification to your portfolio as your account value meets higher
thresholds. For portfolios up to $25,000, your portfolio is managed using five asset class allocations; For portfolios between
$25,000 and $50,000, your portfolio is managed using eight asset class allocations; For portfolios between $50,000 and $100,000,
your portfolio is managed using twelve asset class allocations; For portfolios over $100,000, your portfolio is managed using
fourteen or more asset class allocations. Portfolios that subsequently fall below the investment minimum for a given asset class
allocation will be moved down to the asset allocation appropriate to the portfolio’s value. Lincoln Investment can change or add
asset allocation thresholds at our sole discretion.
³ Periodic Investment Plan minimum of $150 or $10,000 lump sum investment minimum.
4 Minimum investment for AIM Asset Management Program accounts custodied at TIAA is $10,000 lump sum with no Periodic
Investment Plan minimum.
Sub-Advisers to Lincoln Investment Managed Model Portfolio Offerings
(Each Sub-Adviser offers multiple risk level Model Portfolios)¹
Discipline
Sub-Adviser
Investment Types
Custodian of Assets
Dynamic
Mutual Funds
Minimum
Investment
$150/
$10,0002
Dynamic
Clark Capital
Management Group
(CCMG)
DoubleLine Capital LP
$10,000
Mutual Funds
Dynamic
$25,000
Mutual Funds
J.P. Morgan Investment
Management Inc.
Charles Schwab & Co.,
Inc.;
TIAA
Charles Schwab & Co.,
Inc.;
TIAA
Charles Schwab & Co.,
Inc.;
TIAA
1 Model portfolios are available only to residents of the United States.
2 Periodic Investment Plan minimum of $150 for CCMG Multi-Strategy 50/50 model or $10,000 lump sum investment minimum,
all other CCMG models are $10,000 lump sum investment minimum only.
You are responsible to notify your Advisor of any changes in your financial situation, risk tolerance or
investment objectives, and to let us know of any investment restrictions that you wish to impose so that your
Advisor can suggest the appropriate advisory service for you. If you wish to impose investment restrictions,
Lincoln Investment Asset Management Program Model Portfolios may not be the appropriate advisory service
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for you, as they generally cannot be customized to certain investment restrictions.
Please refer to Item 8: Methods of Analysis, Investment Strategies and Risk of Loss for a description of the
primary investment strategies utilized in Lincoln Investment Asset Management Program Model Portfolios.
III. Third-Party Managed Model and Third-Party Custom Portfolios
Co-Adviser
Lincoln Investment, as Co-Adviser, works with third-party money managers and platform providers to provide
you with access to their professional investment management services. Neither Lincoln Investment nor your
Advisor performs the ongoing discretionary asset management in your portfolio; this is done by the third-party
money manager. As Co-Adviser, Lincoln Investment, through your Advisor, is responsible to work with you to
collect all necessary information and documentation, to assist you in selecting the appropriate investment
strategy offered by the money manager and to answer any questions you may have about the money manager
or the managed portfolio. Lincoln Investment and your Advisor assess a separate fee for its services in addition
to the third-party money manager or third-party platform provider’s fee. Please review your investment
advisory agreement, any additional agreements with the third-party platform or money manager and the Form
ADV 2A of the third-party platform or money manager for further information regarding the advisory fee for
your selected manager(s) and the portion of the fee that is paid to Lincoln Investment and your Advisor.
Lincoln Investment as Co-Adviser
Lincoln’s Role
Custodian of Assets
Pentegra Trust Company;
Matrix Trust Company
Platform
Provider
Aspire Financial
Services & Pentegra
Retirement Services
Third-party money
managers Offered
Ladenburg Thalmann Asset
Management; Verity Asset
Management
AssetMark
Assist Client in the
Selection and Review of
Third-Party Money
Managers/Models
Assist Client in the
Selection and Review of
Third-Party Money
Managers/Models
AssetMark Trust
Company; Charles
Schwab & Co., Inc.;
Pershing LLC
Brinker Capital
Investments, LLC
National Financial
Services LLC/Fidelity
Brokerage Services, LLC
AssetMark, Aris and Savos and
Various Independent Money
Managers– Ask for current
approved list of money
managers
Brinker and Various
Independent Money Managers–
Ask for current approved list of
money managers
Goelzer
Goelzer Investment
Management, Inc.
National Financial
Services LLC/Fidelity
Brokerage Services, LLC
Pershing LLC
BNY Mellon
Advisors, Inc.
(formerly Lockwood
Advisors, Inc.)
Assist Client in the
Selection and Review of
Third-Party Money
Managers/Models
Assist Client in the
Selection and Review of
Models
Assist Client in the
Selection and Review of
Third-Party Money
Managers
Orion Portfolio
Solutions
Charles Schwab & Co.,
Inc.;
Matrix Trust Company
Assist Client in the
Selection and Review of
Third-Party Money
Managers/Models
SEI Investment
Management Co.
SEI Private Trust
Company
Assist Client in the
Selection and Review of
Third-Party Money
Managers/Models
Managed Account Link and
Separately Managed Account
Program - Ask for current
approved list of money
managers
Orion Portfolio Solutions and
Various Independent Money
Managers– Ask for current
approved list of money
managers
SEI and Various Money
Managers offered through SEI’s
Managed Account Solutions
program– ask for current
approved list of money
managers
Not all third-party money managers or platform providers are available to all Advisors or all clients, and are subject to change.
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Promoter
Advisors and Lincoln Investment may also act as a Promoter and introduce you to a third-party money
manager. In Promoter relationships, we are not acting as a Co-Adviser. For this introduction, the third-party
money manager will pay Lincoln Investment a Promoter/Referral Fee, which we will share with your Advisor.
This fee, which is typically an ongoing portion of the fee collected from you by the manager, must be
disclosed to you at the time of the introduction. Please refer to the disclosure provided to you at the time of the
referral to determine the fee paid to Lincoln Investment and your Advisor. Please review the money manager’s
ADV Part 2A for more information about their advisory fees.
The following table is a list of third-party money managers for which Lincoln Investment and your Advisor
can act as Promoter for all non-ERISA clients:
Third-Party Managers for Whom Lincoln Investment Acts as a Promoter
Haven Private
Meeder Advisory Service
Resources Investment Advisors
AssetMark
Bernstein Private Wealth Management
Brinker Capital
CLS Investment
Not all third-party money managers or platform providers are available to all Advisors or all clients and are subject to
change.
IV. Periodic Investment Consulting
Advisors may, for a fee, provide periodic investment analysis or advice on assets held at a custodian other than
a custodian with which Lincoln Investment has an advisory relationship; for example, your 401(k) assets held
within your employer's plan. Advisors may assist you in diversifying and risk-adjusting your entire household
of investments. You will enter into a separate written Planning Services Agreement before any services are
performed. Once the investment analysis or advice is delivered, the Planning Services Agreement ends, and
your Advisor will be unable to monitor your assets that are not held at a custodian with which Lincoln
Investment has an advisory relationship. You will need to re-engage with your Advisor for future analysis or
advice. Advisors may charge you for these services through a flat or hourly fee.
V. Financial Planning Services
Advisors may offer comprehensive or limited financial planning services for a fee. Financial planning services
may include, but are not limited to, retirement, college, tax, business succession planning or insurance needs
analysis and assistance with estate distribution matters. Financial planning services are generally provided to
you by your Advisor on a flat fee or hourly fee basis. You will enter into a separate written Lincoln Investment
Planning Services Agreement before any financial services begin. This agreement will describe the services
and fees you and your Advisor have agreed upon.
Many Advisors have earned professional designations that enhance their qualifications to offer these planning
services, but Lincoln Investment does not require the Advisor to maintain a professional designation in order
to offer financial planning services. Ask your Advisor about his or her professional designations or see their
Form ADV 2B Brochure Supplement, which provides their career biographical information and the
professional designations earned.
Information Regarding CFP® Certificants
If your Advisor is a CFP® certificant, they acknowledge their responsibility to adhere to the standards
established in the CFP Board’s Code of Ethics and Standards of Conduct, (“Standards”), including the duty of
care of a fiduciary, as defined by the CFP Board. If you become aware that their conduct may violate the
Standards, you may file a complaint with the CFP Board at www.cfp.net/ethics/file-a-complaint. The Certified
Financial Planner Board of Standards Center for Financial Planning, Inc. owns the certification marks CFP®,
CERTIFIED FINANCIAL PLANNER® and federally registered CFP (with plaque design) in the U.S., which
it awards to individuals who successfully complete the CFP Board’s initial and ongoing certification
requirements.
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While providing financial planning services, Lincoln Investment and Advisor shall act in the capacity of a
fiduciary to you. This means that Lincoln Investment and the Advisor will, while engaged in providing
financial planning services to you, make recommendations in your best interest and not subordinate your
interests to our own. During the course of providing these services, Advisor will make reasonable inquiry into
your objectives, and have a reasonable belief that the advice given will be in your best interest. Lincoln
Investment and Advisor shall also make full and fair disclosure to you of all material facts relating to any
inherent conflicts in the advice that will be given. Our fiduciary duty ends with the delivery of the planning
services engaged under your Planning Services Agreement or the expiration of the term of your Planning
Services Agreement, whichever occurs first, at which point your Advisor will be unable to provide ongoing
monitoring of the plan implementation to you unless you enter into a separate advisory agreement with us.
Clients are in no way obligated to implement their planning services. In addition, clients who wish to
implement their planning services are not obligated to do so through Lincoln Investment. Should the client
choose to implement the recommendations contained in the client’s plan, the implementation of those
recommended strategies is entirely at the client’s discretion. All other fee-based services, such as asset-based
investment advice or asset management services through Lincoln Investment would require that you enter into
a separate written investment advisory agreement.
The following financial planning services may be performed for a fee by your Advisor.
Financial Planning Services for Individuals:
• Cash Flow and Balance Sheet Planning. During this process the Advisor will gather information from
the client to aid in preparing and analyzing the client’s current financial state. This process will include
the preparation and analysis of the client’s personal balance sheet and cash flow statement. The client’s
personal balance sheet is a statement of financial position which shows the client’s assets, liabilities and
net worth as of a given date. The client’s statement of cash flow shows the client’s income and expenses
for a given time period. Both personal financial statements are essential to the planning process as it
would be difficult to help an individual achieve their financial goals and objectives without them.
• Estate Planning. During the estate planning process, the Advisor provides advice to enable the
client to make informed decisions with respect to property ownership and distribution of assets, in light of
current federal and state estate tax rules. Based upon the client’s current situation and
their future goals, the Advisor will review the client’s current estate plan, work with the client’s
estate planning attorney and suggest alternative strategies when appropriate. The estate planning process
involves a discussion of gifting, trusts, wills and the disposition of business interests. Tax consequences
and their implications are identified and evaluated.
• Retirement Planning. The retirement planning process includes an analysis of the client’s
current financial situation, expected retirement date and income needed at retirement. The
Advisor will present planning strategies and techniques that can be used to assist the client in
accumulating wealth for retirement income, or in the appropriate distribution of assets following
retirement. Tax consequences and tax implications are identified and evaluated.
•
Investment Planning. During the planning process, the Advisor will evaluate the client’s
existing investments to provide an overview analysis of current holdings. This process includes
an analysis of the client’s current asset allocation, investment income and/or growth, tax
consequences and tax implications, when applicable. Once the client’s current holdings have been
reviewed, the Advisor may recommend strategies and investment accumulation/distribution techniques.
The strategies and techniques recommended are designed to assist the client with the selection of the
appropriate asset allocation strategy necessary to meet their investment objectives and may provide the
client with investment categories considered by the Advisor to be in the best interest of the client. The
strategies and techniques outlined in the investment plan are designed to assist the client with the
achievement of stated investment goals at the most appropriate risk level for the client. In certain
situations, the Advisor will include a written Investment Policy Statement as part of the Investment Plan,
which states the client’s needs and goals and encompasses a policy under which these goals are to be
achieved. Implementation of the recommendations is at the discretion of the client.
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•
Insurance Planning and Risk Management. During the insurance planning and risk management
process, the Advisor will help analyze and assess the client’s exposure to major
risks that could have a significant adverse impact on the client’s financial picture, such as
premature death, disability or the need for long-term care. Advice is provided on the costs and
benefits of available financial products that exist to reduce such risks. Current insurance coverage will be
reviewed and analyzed.
• Tax Planning. During the tax planning process, the Advisor will work with the client and their tax and/or
legal professionals, as Lincoln Investment does not offer tax or legal advice on such topics as timing of
gifts, property transfers, receipt of social security income and minimum distribution requirements from
retirement accounts to minimize tax obligations.
• Employee Benefit Plan Review. During the employee benefit plan review process, the Advisor
will review and analyze the benefits provided to the client from their employer. Employee
benefits such as retirement plans and insurance will be reviewed to see how they fit into the client’s
overall financial situation.
Financial Planning Services for Business Owners:
• Business Succession Planning. The business succession planning process includes an analysis of the
current state of the business and the client’s goals, as a business owner, for the future of the client’s
business. Once the current state of the client’s business and their goals for the future of the business have
been determined, alternatives and strategies addressing the continuity or disposition of the client’s
business upon their retirement, death, disability or decision to sell are provided. Tax consequences and
their implications are also identified and evaluated.
• Executive Compensation Planning. The focus of executive compensation planning is the
analysis and recommendation of various compensation strategies to attract, retain and reward key
employees in the business. This planning may also include the business owner. Objectives of the business
owner and the financial and legal structure of the business will be reviewed and taken into consideration
in the analysis and recommendations. Tax consequences and tax implications are identified and
evaluated. In all matters, planning services are analytical and advisory only, and do not include any legal,
accounting or other professional services.
• Nonqualified Deferred Compensation Planning. Services are offered to clients with regard to
nonqualified benefits planning for employees. Such plans will reflect their current situation and
an analysis of alternative ways to accomplish their compensation objectives. With respect to a
nonqualified deferred compensation program, the analysis contains alternative methods to
informally "fund" the program, including an overview of the accounting treatment of such
alternative methods within the program and a recommendation as to the appropriate method of
"funding" for that employee.
In addition, an Advisor may perform certain administrative services on behalf of clients for a nominal fee.
Monitoring or updating of a plan will only occur if a client implements plan recommendations through
an Advisor under a separate advisory agreement. Lincoln Investment does not provide tax or legal
advice. Please consult with your personal attorney and tax accountant.
VI. ERISA Retirement Plan Advice
Lincoln Investment and its Advisors provide investment advice to sponsors of ERISA retirement plans, as well
as education and enrollment services to eligible participants of the plans. At the plan level, Lincoln Investment
assists the responsible plan fiduciary in analysis, selection, and monitoring of investment options made
available to plan participants. Lincoln Investment may recommend its Lincoln Investment managed model
portfolios, which are managed on a discretionary basis by Lincoln Investment, Advisor Managed Model
Portfolios or Custom Portfolios, which are managed on a non-discretionary basis by the plan’s Advisor, a Sub-
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Adviser or a third-party money manager. Advisors of Lincoln Investment may also assist eligible participants
of these plans in education and enrollment. Lincoln Investment may also assist the responsible plan fiduciary
in the selection of a product sponsor’s program or third-party platform. Below is a list of approved platforms.
ERISA Approved Third-Party Advisers and Platforms
OneAmerica
PAi – RIA
PayChex
PenServ
Pershing
Principal Financial
SBL – Variflex
Securian
SEI Private Trust
Spectrum Employee Benefits – RIA
Summit Benefit Solutions/July Business Services – RIA
Sunwest Pensions – RIA
The Pacific Financial Group
T. Rowe Price
The Standard
Transamerica
Ubiquity
Voya (ING)
ADP
Alliance Bernstein
American Funds – Recordkeeper Direct
Ameritas Advantage Elite - Annuity
Ascensus
Aspire Financial Services
AssetMark Retirement Services
CUNA (formerly CPI)
Employee Fiduciary
Empower Retirement (Great West)
Fidelity Advisors
Human Interest
IFP/Montgomery Retirement Advisors
J. P. Morgan
John Hancock
K Trade
Lincoln Financial – Director
Mass Mutual
Nationwide
Assets Under Management
As of December 31, 2025, Lincoln Investment and its Advisors managed or advised over $22.9 billion in advisory
assets:
•
•
$12.9 billion in advisory assets on a discretionary basis, and
$10 billion in advisory assets on a non-discretionary basis.
Item 5: Fees and Compensation
This section provides to you a description of our advisory fees, how and when these advisory fees are collected, and
if refunds are available. Other types of fees and expenses that you may incur are described below in the section
titled, "Other Costs That You May Incur." Details regarding other compensation received by Lincoln Investment
and your Advisor and associated conflicts of interest are described in the section titled "Other Compensation to
Lincoln Investment and Our Conflicts of Interest."
For all advisory services offered by Lincoln Investment, the specific manner in which advisory fees are calculated
and charged is described in your investment advisory agreement. In your agreement, you also authorize Lincoln
Investment to directly debit advisory fees from your account. Lincoln Investment can waive or negotiate advisory
fees at our sole discretion.
When you engage Lincoln Investment, your costs will depend on the Program(s) and custodian selected, your
Advisor’s fee, whether the account will be comprised of mutual funds or ETFs that have their own internal expenses
and transaction costs, and whether you choose a Wrap or non-Wrap Fee Program.
I. How You Compensate Your Advisor and Lincoln Investment; Advisor Consulting, Client Custom
Portfolios and Advisor Managed Model Portfolios
Your Advisor is compensated for investment advice by an advisory fee that is based on the value of the assets
in your advisory account (“Financial Advisor Fee”). This advisory fee continues for as long as you maintain
your account with your Advisor. This fee provides access to your Advisor for financial and life planning
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consultation, as requested by you, which includes assisting you in the determination of the appropriate
investment advisory investments and advisory programs for you and conversing with you on an as-needed or
as requested basis to ensure that the investments and programs continue to meet your stated objectives and
needs. Your Advisor has a choice of platforms to recommend for the custody of your assets. The advisory fee
for advisory services offered to you can differ by Advisor, whether the Advisor is providing consultation, asset
management or advice, what investments are available on the platform (e.g., a mutual fund only or mutual
funds and other general securities offerings) and whether the advice to be provided by the Advisor is with or
without discretionary authority.
Your Advisor’s fee is negotiable at the Advisor’s sole discretion and to a maximum fee that is established by
Lincoln Investment. Your Advisor will share in all or a portion of the Financial Advisor Fee based on their
payout schedule with Lincoln Investment. The maximum annual Financial Advisor Fee that your Advisor can
charge for his/her services is 1.25% of the assets being advised or managed.
The specific fee and billing parameters for your managed or advised portfolio is provided within the
investment advisory agreement you sign prior to the start of advisory services. Consult with your Advisor to
learn more about the advisory services and fees he or she offers.
Lincoln Signature Solutions – Client Custom Portfolios Program
If you select the Client Custom Portfolios Program available on the Lincoln Signature Solutions platform, in
addition to the Financial Advisor Fee, you will pay an annual, asset-based Platform Fee depending upon your
account type, as outlined in the tables below.
Platform Fee
Workplace Retirement Solutions
Wealth Solutions (Applicable to non-
403(b)/457(b) accounts)
Assets
Assets
First $500,000
$500,000.01 - 1,000,000
$1,000,000.01 - 2,000,000
$2,000,000.01 – 5,000,000
$5,000,000.01 – 10,000,000
$10,000,000.01 – 20,000,000
$20,000,000.01 – 35,000,000
Over $35,000,000
Platform
Fee
0.15%
0.12%
0.10%
0.08%
0.06%
0.04%
0.03%
0.02%
(Applicable to 403(b)/457(b) accounts)
Platform
Fee
0.24%
First $500,000
0.21%
$500,000.01 - 1,000,000
0.19%
$1,000,000.01 - 2,000,000
0.17%
$2,000,000.01 – 5,000,000
$5,000,000.01 – 10,000,000
0.15%
$10,000,000.01 – 20,000,000 0.15%
$20,000,000.01 – 35,000,000 0.15%
0.15%
Over $35,000,000
Lincoln Wealth Solutions Client Custom Portfolios Program - Maximum Annual Advisory Fee
Program
Max. Platform Fee
Max. Total Fee
CCP¹
Max. Financial Advisor
Fee
1.25%
0.15%
1.40%
1 Client Custom Portfolios (CCP) Accounts are subject to a minimum annual Platform Fee of $100.00 per year, not to exceed
0.25%. This fee is assessed at $8.33 per month. Minimum investment amounts can vary by Advisor.
Lincoln Workplace Retirement Solutions Client Custom Portfolios Program - Maximum Annual Advisory Fee
Program
Max. Platform Fee
Max. Total Fee
CCP¹
Max. Financial Advisor
Fee
1.25%
0.24%
1.49%
1 Minimum investment amounts can vary by Advisor.
In addition to the Financial Advisor Fee described above, Lincoln Investment makes certain payments to your
Advisor upon meeting certain requirements, including, but not limited to, attaining or maintaining asset or new
account enrollment thresholds. For additional details regarding these payments including the criteria for
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selection and associated conflicts of interest, see Other Compensation to Lincoln Investment and Our Conflicts
of Interest.
II. Lincoln Investment Asset Management Programs: Model Portfolios Managed by Lincoln
Investment
If you choose a Lincoln Investment managed model portfolio, you will pay an Asset Management Program
Fee to Lincoln Investment. The Asset Management Program Fee is in addition to the Financial Advisor Fee
described above and will vary by offering and platform. See your investment advisory agreement for the
specific management fees assessed to you for your selected program.
Sub-Advisers offered by Lincoln Investment do not charge Lincoln Investment for providing Model Portfolios;
instead, these Sub-Advisers are compensated directly or indirectly by their affiliated mutual funds that are
utilized in their Model Portfolios. The underlying mutual funds that are utilized in Lincoln Investment Asset
Management Program Model Portfolios are unaffiliated with Lincoln Investment. Lincoln Investment has
employed its IM&R Team to manage its Model Portfolios and to oversee the Asset Management Program
Model Portfolios provided by Sub-Advisers.
The IM&R Team has final approval on all portfolio decisions related to Lincoln Investment’s Model Portfolio
offerings and is described in more detail in the ADV 2B Brochure Supplement accompanying this brochure.
When you select certain advisory programs and/or platforms, Lincoln Investment earns additional fees. For
example, Lincoln Investment earns a Manager Fee when you select advisory programs professionally managed
by IM&R. Lincoln Investment has a financial incentive to promote these advisory programs and/or platforms
to generate additional revenue.
III. Third-Party Managed Model and Third-Party Custom Portfolios
Co-Adviser
Lincoln Investment, as Co-Adviser, works with third-party money managers to provide you with access to
their investment advisory services. In some instances, a portion of the Advisory Fee charged by the third-party
money manager is paid to Lincoln Investment and your Advisor; in other instances, your Advisor may add on
a fee to the money manager’s fee for certain assigned services provided as Co-Adviser. Please review your
investment advisory agreement, any agreements with the third-party platform or money manager and the Form
ADV 2A of the third-party platform or money manager for further information regarding the advisory fee for
your selected manager(s) and the portion of the fee that is paid to Lincoln Investment and your Advisor.
Promoter
Advisors and Lincoln Investment may also act as a Promoter and introduce you to a third-party money
manager. In Promoter relationships, we are not acting as a Co-Adviser. For this introduction, the third-party
money manager will pay Lincoln Investment a Promoter/Referral Fee, which we will share with your Advisor.
This fee, which is typically an ongoing portion of the fee collected from you by the manager, must be
disclosed to you at the time of the introduction. Please review the disclosure provided to you at the time of the
referral to determine the fee paid to Lincoln Investment and your Advisor. Please review the third-party money
manager’s ADV Part 2A for more information about their advisory fees.
IV. Periodic Investment Consulting
Advisors may, for a fee, provide periodic investment analysis or advice on assets held at a custodian other than
a custodian with which Lincoln Investment has an advisory relationship; for example, your 401(k) assets held
within your employer's plan. Advisors may assist you in diversifying and risk-adjusting your entire household
of investments. You will enter into a separate written Planning Services Agreement before any services are
performed. Once the investment analysis or advice is delivered, the Planning Services Agreement ends, and
your Advisor will be unable to provide ongoing monitoring of your assets that are not held at a custodian with
which Lincoln Investment has an advisory relationship. You will need to re-engage with your Advisor for
future analysis or advice. Advisors may charge you for these services through a flat or hourly fee.
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V. Financial Planning
Financial Planning services are generally provided to you by your Advisor on a flat fee or hourly fee basis.
You will receive a written fee for services agreement before any financial services begin. This agreement will
describe the services and fees you and your Advisor have agreed upon.
For the Planning Services offered by Lincoln Investment’s Advisors, the specific manner in which you
compensate your Advisor is described in your Planning Services Agreement. Fees may be quoted as either
hourly or a flat fee for services to be rendered. Fees are negotiable and can vary based on the type and level of
service provided. Advisors will take the following factors into consideration when determining the fee to be
assessed to you:
1. The amount of time the Advisor expects to spend completing the particular services and providing
related advice.
2. The complexity of your financial planning issues and needs.
3. The extensiveness and complexity of the data to be collected in order to perform the services.
4. Your net worth or value of investment accounts and/or other assets that are the subject of the
Planning Services.
5. Special circumstances related to a life change, marital status, health or special income needs, or
growth or decline of a personal business.
Ask your Advisor for their fees for Planning Services. Each office, and in some instances each Advisor of
Lincoln Investment, has his/her own fee schedule; therefore, the cost of similar services by another Advisor
may be higher or lower than the fee schedule quoted by your Advisor. Fees may also vary among clients due to
the complexity of the planning or the depth of the services provided. Thus, a client’s quoted fee may be higher
or lower than the fee quoted to another client.
Additional Information Regarding Paying for Services
Your Advisor decides how he/she will be compensated for the Planning Services. It can be collected in full or
in part in advance of services rendered, but no later than 30 days after services are rendered or delivery of the
completed plan. You may be entitled to a refund of unearned Fees paid in advance, if any, taking into account
the time, effort and extent of planning services already performed by the Advisor for you prior to receipt of
your written notice to terminate the Planning Services Agreement.
VI. ERISA Retirement Plan Advice
Fees for advice and services provided to ERISA retirement plans are negotiable between Lincoln Investment,
the Advisor and the plan sponsor. For plans governed by ERISA, compensation arrangements may involve the
offset or refunding of any indirect compensation received by Lincoln Investment that could be deemed a
prohibited transaction relating to the assets or transactions in the plan, such as 12b-1 fees. Compensation will
be described in the 408(b)(2) disclosure provided when your ERISA account is established.
Additional Information Regarding Fee Billing
An expense within some mutual fund share class offerings is a Mutual Fund Distribution Fee, also called a 12b-1
fee, which is paid to your broker-dealer. For advisory accounts held on the Pershing platform, the amount of the
12b-1 fee received by Lincoln Investment will be refunded directly to your Pershing account. This crediting of 12b-
1 fees will alleviate the conflict of interest associated with Lincoln Investment receiving this third-party
compensation and will also reduce the expense to you associated with purchasing a mutual fund share class which
includes a 12b-1 fee expense. You may still incur a 12b-1 fee expense for any portion of the 12b-1 fee expense that
the fund does not share with your broker-dealer custodian or that your broker-dealer custodian does not share with
Lincoln Investment. Whether you receive and the manner in which you receive this credit depends on the platform
where your advisory assets are held.
For assets held on the Pershing platform, Lincoln does not assess (1) pro-rata fees for deposits or (2) pro-rata
refunds for withdrawals, but will assess a pro-rata fee for accounts opened during the month and issue pro-rata
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refunds for terminations. See your investment advisory agreement for pro-rata fee assessments and refunds
thresholds, as these vary by platform and program. Fees are payable first from the designated sweep position or free
credit balance, as applicable. In addition, if there are insufficient funds, account assets will be liquidated to satisfy the fee
obligation, debit balance or anticipated debit balance. Any excess proceeds of the liquidation will remain in the account’s
sweep position or free credit balance, as applicable, until client instructs Advisor or Lincoln Investment to move assets to
another investment. An investor may terminate Lincoln Investment’s or its Advisor’s advisory services at any time upon
written notice to us. Lincoln Investment’s notice of the death of investor will immediately terminate advisory services. The
executor or other authorized representative may elect to re-engage Lincoln Investment to continue to provide advisory
services. Upon termination of advisory services, any unearned fees collected in advance will be refunded on a pro-rata
basis. Lincoln Investment will not refund unearned Fees that total less than $1.00.
For assets held on platforms other than Pershing, see your investment advisory agreement for billing details,
including the frequency of fees assessment as well as whether your fee is assessed in advance or arrears of services
rendered, as these vary by platform. Threshold levels for initial and interim billing for deposits and withdrawals can
vary based on platform and program.
You could purchase products or services similar to those offered by Lincoln Investment separately from our
affiliated investment adviser, Capital Analysts, LLC or from any financial services provider. Lincoln Investment
offers some employer sponsored retirement plans, current and former employees, its Advisors and family members a
discount or waiver of some or all fees. Lincoln Investment can waive or negotiate fees at our sole discretion.
Wrap Fee Programs
A Wrap Fee Program is an investment advisory program in which you pay one bundled fee to compensate Lincoln
Investment and your Advisor for their services and to pay the transaction and clearing costs associated with
transactions in your advisory account. Lincoln Investment offers Wrap Fee Programs on some third-party platforms,
such as Pershing. A Wrap Fee is not based directly upon the actual transaction or execution costs of the transactions
in your account. Depending on the underlying investments and amount of transactions you expect in your account, a
Wrap Fee account may cost you more or less than if you chose a Lincoln Investment advisory program that does not
charge a Wrap Fee, or if you chose to pay separately for all of your transaction costs (e.g., pay the advisory fee plus
all transaction costs). In general, you should only choose a Wrap Fee Program if you or your Advisor expect to trade
regularly in the account. For further information regarding Lincoln Investment’s Wrap Fee Programs, please see
Lincoln Investment’s Wrap Fee Program Brochure (Form ADV Part 2A Appendix I) attached.
On third-party platforms, there may be transaction costs associated with acquiring or selling securities. If you expect
to do significant trading in your account, a Wrap Fee may be a more cost-efficient advisory account fee arrangement
for you. Transaction Fee (TF) and No Transaction Fee (NTF) mutual funds are available on many of the third-party
provider platforms, such as Pershing, Fidelity and Schwab. Mutual funds with no transaction fees can have higher
expense ratios, which can adversely affect the long-term performance of your portfolio when compared to share
classes of the same fund with lower internal expenses. If a Transaction Fee fund is selected, you could be assessed a
transaction-related fee such as a ticket charge or mutual fund surcharge fee, unless you are in a Wrap Fee program.
If you wish to consider a Wrap Fee program, Lincoln offers Wrap Fee programs on Pershing, and for a limited
number of advisors, on Schwab. See Lincoln Investment’s Wrap Fee Brochure for more information.
Other Costs That You May Incur
Total advisory fees paid and other costs associated with your portfolio impact the overall performance of your
portfolio. It is important to review these costs when making your advisory and investment decisions.
Costs may include the following:
1. Mutual Fund 12b-1 Distribution Fees. An expense within some mutual fund share class offerings is a
Mutual Fund Distribution Fee, also called a 12b-1 fee, which is paid to your broker-dealer. For advisory
accounts held on the Pershing platform, the amount of the 12b-1 fee received by Lincoln Investment will be
refunded directly to your Pershing account. This crediting of 12b-1 fees will alleviate the conflict of interest
associated with Lincoln Investment receiving this third-party compensation and will also reduce the expense
to you associated with purchasing a mutual fund share class, which includes a 12b-1 fee expense. You may
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still incur a 12b-1 fee expense for any portion of the 12b-1 fee expense that the fund does not share with your
broker-dealer custodian or that your broker-dealer custodian does not share with Lincoln Investment. Whether
you receive and the manner in which you receive this credit depends on the platform where your advisory
assets are held.
2. Internal Expenses. Internal management fees and other fund fees or expenses are charged by the mutual fund
or sub-account of a variable annuity (also known as the internal expense). All mutual funds, ETFs and annuity
companies charge a fee for the management and operations of their offerings. Higher internal expenses can
adversely affect the long-term performance of your portfolio when compared to share classes of the same fund
that assess lower internal expenses. For more complete information regarding the internal expenses of an
investment and how they impact your costs and performance, you should read “Understanding Share Classes
within your Investment Advisory Accounts” below.
3. Platform Fees. Lincoln Investment offers its advisory services on various broker-dealer platforms. Each
platform assesses different account fees, such as platform fees, ticket charges, commissions, wire fees, trade-
away fees, statement and confirmation fees, retirement plan recordkeeping or custodial fees and low balance
or account termination fees. Depending on the platform/custodian selected, some fees can be avoided or
reduced. For instance, applicable fees will be different for an account opened on Pershing versus another
third-party platform/custodian. Platforms/custodians can waive or negotiate their respective fees assessed to
you, Lincoln Investment, and/or your Advisor, in each platform/custodian's sole discretion. For a description
of trading and administrative fees associated with where your account will be held, view the specific
disclosure document for your applicable platform found at www.lincolninvestment.com/Disclosures. Also,
please refer to Item 12: Brokerage Practices for further information.
4. Mutual Fund Surcharge Fees. Some custodians and platforms assess a surcharge fee for transactions in
certain mutual fund share classes, typically to offset the costs of providing services when the mutual fund does
not pay the custodian or platform directly.
5. Mutual Fund Short-term Trading Redemption Fees. Some mutual funds impose short-term trading
redemption fees of up to 2% for active trading or exchanging in and out of their funds. This could affect you
or the ability of Lincoln Investment, your Advisor or third-party manager to properly manage your portfolio
as these costs will impact the performance of your portfolio or may be an incentive not to trade.
6. Variable Annuity Rider and Contract Costs. These costs may include, but are not limited to, annual base
annuity contract charges, optional benefit riders, underlying sub-account fees and expenses, and potential
surrender fees.
7. Retirement Plan Rollovers. If you decide to roll assets out of a retirement plan, such as a 401(k) plan, into an
individual retirement account ("IRA"), we have a financial incentive to recommend that you invest those
assets with us because we will be paid an advisory fee on those assets, and other compensation. You should be
aware that such fees would likely be higher than those you would pay through the plan, and there can be
additional costs and expenses, such as custodial fees and account fees. As securities held in a retirement plan
are generally not transferred to an IRA, commissions and sales charges may be assessed when liquidating
such securities prior to the transfer, in addition to commissions and sales charges previously paid on
transactions in the plan. For more information about rollovers, see The Lincoln Investment Companies
Investor Agreement and Disclosure Handbook.
You could incur additional charges imposed by custodians, broker-dealers, investment and insurance companies and
other third parties, such as transfer taxes, wire transfer and electronic fund fees and other fees and taxes on
brokerage accounts and securities transactions. Such charges and fees are exclusive of and in addition to Lincoln
Investment’s fee. You shall be responsible for payment of any and all taxes that may be due as a result of any
transactions in your account.
Other Compensation to Lincoln Investment and Our Conflicts of Interest
Lincoln Investment recognizes its fiduciary responsibility to place your interests above ours and that other
compensation received by us, or an affiliate, from other sources presents a conflict of interest and could be looked
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upon by you as an incentive for us to recommend investment products or advisory services based on compensation
rather than on your financial needs. Below is a description of conflicts of interest that we have identified in the
conduct of our business that we believe may be material. With many of these conflicts, we have taken steps to
mitigate or reduce the conflict.
Understanding Share Classes in Lincoln Investment Advisory Accounts
Mutual funds are common investments for individuals. A mutual fund pools money from many investors and invests
the money in securities or other assets. A mutual fund has various expenses that are paid from fund assets. These
internal expenses are reflected in the fund's "expense ratio." Such expenses include fees paid to the adviser that
manages the fund, operational expenses, and fees paid to the brokers that sell shares of, and provide services to, the
fund. These are ongoing fees and expenses charged throughout the life of the mutual fund investment. Fees and
expenses are an important consideration in selecting a mutual fund because these charges lower an investor's returns.
A mutual fund frequently offers investors different "share classes." Each class will invest in the same "pool" or
portfolio of securities and other assets, but each class will have different fees and expenses and, therefore, different
returns. For example, some share classes have higher expense ratios because they pay brokers more for selling or
servicing that particular share class. In contrast, other share classes of the same fund may have lower internal fees
and expenses. A single mutual fund will often have share classes with different expense ratios, with the share classes
that have higher expense ratios generally having lower returns than share classes with lower expense ratios. In other
words, an individual investor may pay more, or less, for precisely the same mutual fund investment, depending on
the share class. These internal fees and expenses are in addition to any fees a broker may directly charge customers
on particular share classes, including transaction-related fees, such as surcharge fees, at the time of buying or selling
the fund shares, and are in addition to the investment advisory fee you will pay.
The expense ratio of a fund is disclosed in the fund’s prospectus and annual reports and generally reflects the annual
operating costs of the fund, assessed as a percentage of a fund’s average assets. The expense ratio within a mutual
fund share class can fluctuate from what is shown in a prospectus for the fund offering and annual report and can
vary over time and from year to year. A fund that was deemed to have a lower expense ratio at the time of purchase
may not actually maintain that expense ratio during the time that the fund is held and new fund share classes may
become available with different expense ratios.
Lincoln Investment looks at the “Prospectus Net Expense Ratio” as provided by a third-party data provider for each
mutual fund share class to determine the least expensive eligible share class. The Prospectus Net Expense Ratio is a
fund’s stated total annual operating expense percentage after any contractual fee waivers or other expense
reimbursements to the fund.
Lincoln Investment’s Share Class Selection Policy for Advisory Accounts
This share class selection policy applies to your advisory assets that are custodied at Pershing LLC (“Pershing”) and
for which Lincoln Investment and/or your financial professional initiate the trade and is described below. For your
advisory assets custodied at Pershing utilizing an overlay manager, the share class designated by Lincoln Investment
is subject to the approval of your overlay manager. The overlay manager can choose to utilize a share class in your
account that differs from the policy outlined below. If applicable, please see your overlay manager’s Form ADV 2A
and/or Appendix I for additional details.
Although you are purchasing at net asset value of the fund, there are internal expenses built into every mutual fund
that can impact the performance of your investment over time. Regardless of whether you have selected a
discretionary or non-discretionary advisory program, share class selection for your mutual fund purchases within
your advisory account will be determined by Lincoln Investment. Share class expenses can vary across different
share classes of the same fund. In furtherance of its fiduciary duty to advisory clients, Lincoln Investment will seek
to select the least expensive share class available on the applicable custodial platform for the selected mutual fund
for which all of our retail advisory accounts will be eligible (except that money market mutual funds within the
Sweep Program and 403(b)7/457(b) accounts are treated differently, each as described below). For purposes of this
policy, the least expensive share class is defined as the share class of a mutual fund that has the lowest prospectus
net expense ratio as published by the third-party data provider (or a share class with a net expense ratio that is no
greater than ten basis points (0.10%) different than such share class with the lowest net expense ratio), subject to the
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share classes’ investment minimums being appropriate for all of our retail advisory investors, obtaining investment
minimum waivers where they are available, and selecting a share class that is available to all investors regardless of
account tax type. In addition, due to specific mutual fund company constraints, situations will arise where Lincoln
Investment chooses a share class that does not have the lowest prospectus net expense ratio in that mutual fund in
order to remain consistent with the share classes of other mutual funds within a particular fund family available on
our platform.
Accounts on the Lincoln Workplace Retirement Solutions platform for 403(b)/457 accounts custodied at Pershing in
the Client Custom Portfolios (advisor-managed) program are subject to a No Surcharge Fund First (“NSFF”) policy,
as described below. The No Surcharge Fund First (“NSFF”) policy is applicable to Client Custom Portfolios
(advisor-managed) 403(b)/457(b) accounts only. Under the NSFF policy, for fund families that offer certain share
classes that assess a surcharge, Lincoln Investment will make available the share class with the least expensive
internal expense ratio that does not assess a surcharge fee. If the fund family does not offer a share class without a
surcharge fee, Lincoln Investment will make available the share class with the least expensive internal expense ratio
and the surcharge fee will be assessed. Generally, and subject to additional conditions, the designated share class
will be ascertained by designating the share class with the lowest internal expense ratio for which no surcharge fee
applies and all 403(b)/457(b) accounts on the Pershing platform will be eligible. Where all share classes of a mutual
fund assess a surcharge fee, that surcharge fee fund will remain available subject to the surcharge fee discussed
above and in the Lincoln Investment Trading Fees, Account Service Fees and Disclosures – Accounts Held on
Pershing Platform.
In addition to the share class selection factors described above, Lincoln Investment will also consider various other
factors when considering share class conversions in your advisory accounts, including but not limited to, whether
the fund will allow tax-free conversions, as well as whether there is a ten basis point (0.10%) or greater difference in
the expense ratio between the existing share class and the new, proposed share class. The fund share class used in a
discretionary Lincoln Investment Managed Model Portfolio can be different than the fund share class used in other
Lincoln Investment advisory accounts, including accounts managed by your financial professional, as a fund
minimum waiver may be available for discretionary Lincoln Investment managed model portfolios but not for other
types of advisory accounts, such as accounts managed by your financial professional. Most mutual funds offer
varying share classes, but all custodians may not make all share classes of a mutual fund available; therefore, the
designated share class selected by Lincoln Investment will likely vary across custodial platforms.
If the fund and share class selected includes a 12b-1 fee, Lincoln Investment will continue to credit back to your
advisory account any 12b-1 fee revenue received by the firm on behalf of your advisory assets to eliminate the
conflict of interest associated with the receipt of such revenue.
Lincoln Investment will review available mutual fund share classes periodically to identify share classes that must
be changed in order to align with this policy. If a different share class is identified that meets our policy criteria as
described herein, Lincoln Investment will initiate a share class conversion for all mutual fund investments in those
share classes. In addition, for accounts subject to the NSFF policy, if it is determined that a mutual fund share class
that does not assess a surcharge fee is available and meets our policy criteria as described above, Lincoln Investment
will initiate a share class conversion for all mutual fund investments in the surcharge fee share class to that no
surcharge fee share class (except that money market mutual funds within the Sweep Program are treated differently,
as described below). Share class conversions will appear on your account statements. The ability and length of time
to affect a share class conversion will vary and is subject to prospectus requirements and custodial platform
approval. If you transfer-in shares of a mutual fund into an advisory account that are in a share class with a lower
internal expense ratio than the share class available in your advisory program, Lincoln Investment can convert your
mutual fund position to the share class of that fund that meets our policy criteria as described herein (including a
share class with a higher internal expense ratio). Lincoln Investment can also restrict additional purchases of a share
class and convert any grandfathered share class during a periodic review. For accounts subject to the NSFF policy, if
you transfer-in shares of a mutual fund that assesses a surcharge fee, Lincoln Investment will convert your mutual
fund position from a mutual fund share class that assesses a surcharge fee to a share class that does not assess a
surcharge fee, if available.
Not all mutual funds and share classes available to the investing public will be available to Lincoln Investment
and/or available for use in your advisory program. You should not assume that you are or will be invested in the
least expensive share class available, and the share class of a mutual fund offered by Lincoln Investment can have
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higher expenses, and therefore lower returns. Additionally, Lincoln Investment has selected a higher-cost share class
with respect to the Dreyfus Government Cash Management Fund – Service Shares Sweep Product, which is the
designated sweep product for non-ERISA 403(b)7 and 457(b) plans and participant accounts and the designated
secondary sweep product for excess balances in the Dreyfus Insured Deposits L Sweep Product. There are less
expensive share classes of the same money market mutual fund available that would not provide revenue sharing
with the firm or would provide lesser amounts of revenue sharing with the firm.
Information about the mutual funds and share classes that are available through your account, including their
investment policies, restrictions, charges and expenses, is contained in the mutual funds’ prospectuses. You should
read these prospectuses carefully.
Third-Party Payments to Lincoln Investment
Third-Party Payments and Revenue Sharing from Pershing
In our role as introducing broker-dealer for assets held at Pershing, Pershing provides credits, payments and benefits,
including but not limited to fee and expense reductions, that incentivize us to recommend and continue to use
Pershing as clearing firm and custodian and achieve agreed upon asset levels in The Bank of New York Mellon
Corporation (“BNY”)’s affiliated products and services. Pershing and BNY Mellon Advisors, Inc. (“BNYMA”) are
affiliates of BNY.
Pershing Revenue Sharing, Payments and/or Expense Credits with Lincoln Investment. For accounts held
on Pershing’s platform, Pershing provides certain credits and payments to Lincoln Investment, as introducing
broker-dealer, pursuant to a written agreement in consideration of the extension and/or continuation of Lincoln
Investment’s current agreement with Pershing. Lincoln Investment does not refund or offset these
credits/payments against fees paid by clients. This revenue does not vary with respect to the investment
choices/recommendations made in your Pershing account. Overall, the expense credits received by Lincoln
Investment from Pershing for 2025 as allocated to the firm and its affiliates represented less than one percent of
Lincoln Investment’s total advisory revenue, less than one percent of Capital Analysts’ revenue and less than one
percent of Lincoln Investment’s broker-dealer revenue. The receipt of these expense credits and payments create
a conflict of interest to Lincoln Investment to recommend and/or use Pershing as a custodian over other
custodians that do not share these fees, do not provide expense credits/payments to us or that would share lesser
amounts with us. Additionally, under our agreement with Pershing, there is a termination fee schedule with
amounts that decrease over time. Therefore, Lincoln Investment has an incentive to maintain the relationship
with Pershing for a longer period of time. We mitigate these conflicts by disclosing them to you and by not
sharing the credits/payments with your Advisor.
Pershing Margin Participation. For advisory and brokerage accounts held on Pershing’s platform, Lincoln
Investment, as introducing broker-dealer, marks up the base interest rate pursuant to a written agreement with
Pershing, resulting in a higher margin interest rate to you. This mark-up will not exceed 2.25% above the base
interest rate. The receipt of revenue sharing with Pershing creates a conflict of interest to Lincoln Investment to
use Pershing as custodian over other custodians that do not permit us to mark-up the fees or limit the amount.
Lincoln Investment mitigates this conflict by disclosing it to you and by not sharing it with your Advisor.
Pershing Non-Purpose Loan Markups. For advisory and brokerage accounts held on Pershing’s platform,
Lincoln Investment, as introducing broker-dealer, marks up the base interest rate pursuant to a written agreement
with Pershing, resulting in a higher non-purpose loan interest rate to you. This mark-up will not exceed 0.75%
above the base interest rate. The receipt of revenue sharing with Pershing creates a conflict of interest to Lincoln
Investment to use Pershing as custodian over other custodians that do not permit us to mark-up the fees or limit
the amount. Lincoln Investment mitigates this conflict by disclosing it to you and by not sharing it with your
Advisor.
Trading and Account Service Fees. Lincoln Investment establishes brokerage commission schedules for its
advisory and brokerage accounts. For accounts held on Pershing’s platform for which Lincoln Investment is
introducing broker-dealer (i) Pershing charges trading and account service fees for which Lincoln Investment, as
introducing broker-dealer, has added a mark-up that ranges from 0% to 420%; (ii) For certain trading and
account services for which Pershing does not assess a fee to Lincoln investment, Pershing permits Lincoln
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Investment, as introducing broker-dealer, to impose its own fee which is charged to you. The receipt of these
fees creates a conflict of interest for Lincoln Investment since it creates an incentive for Lincoln Investment to
continue to use Pershing as custodian over other custodians that do not permit us to mark-up the trading and
account service fees or would limit the amount, or that would not permit us to set our own fee. We mitigate these
conflicts by disclosing them to you and by not sharing the mark-ups and Lincoln Investment fees with your
Advisor. Your Advisor is permitted to pay certain fees on your behalf in their sole discretion.
Growth Incentive Credits/Payments. For accounts opened and/or assets moved to Pershing by Lincoln
Investment or its affiliate, Capital Analysts, Pershing provides a credit/payment to Lincoln Investment based on
the total asset value of such accounts when the accounts are opened on Pershing, or accounts/assets are moved to
Pershing or retained by Pershing, pursuant to a written agreement with Pershing. The receipt of these
credits/payments creates a conflict of interest to Lincoln Investment and its affiliate, Capital Analysts, to
recommend and/or use Pershing as a custodian over other custodians that do not share these fees, do not provide
credits/payments to us or that would share lesser amounts with us. This revenue is not shared with your Advisor.
Acquisition Financial Support Credits/Payments. For accounts acquired from other firms by Lincoln
Investment or its affiliate, Capital Analysts, Pershing provides a credit/payment to Lincoln Investment based on
the total asset value of such accounts when they will be moved to Pershing or retained by Pershing, pursuant to a
written agreement with Pershing. The credit/payment provided to Lincoln Investment is greater for acquired
accounts that will be moved to Pershing compared to the credit for acquired accounts that will be retained by
Pershing (accounts already existing on Pershing’s platform). The receipt of these credits/payments creates a
conflict of interest to Lincoln Investment and its affiliate, Capital Analysts, to recommend and/or use Pershing as
a custodian over other custodians that do not share these fees, do not provide credits/payments to us or that
would share lesser amounts with us. This revenue is not shared with your Advisor.
The Lincoln Investment Companies Sweep Program. The Lincoln Investment Companies offer a sweep
program (“Sweep Program”) under which uninvested cash or “free credit balances” in your eligible accounts that
are custodied with Pershing are automatically invested or deposited (“swept”) into money market mutual fund(s)
(“Money Fund Sweep Products”), or bank deposit sweep product(s) eligible for FDIC insurance protection up to
$2.5 million (“Bank Deposit Sweep Products”) (collectively referred to as “Sweep Product(s)”), which consist of
interest-bearing bank deposit accounts (“Deposit Accounts”) at Federal Deposit Insurance Corporation (“FDIC”)
member banks. The member banks (“Program Banks”) can include The Bank of New York Mellon (“BNY”) and
BNY Mellon, N.A., banking affiliates of Pershing or other banking affiliates of Pershing. When participating in
the Sweep Program, you appoint Pershing as your authorized agent to establish and maintain Deposit Accounts
at various Program Banks. The Bank Deposit Sweep Products and Money Fund Sweep Products are supported
and operated through a private labelling arrangement with Dreyfus, a division of Mellon Investments
Corporation (“MIC”) and are available only to clients of broker-dealers who clear through Pershing, such as
Lincoln Investment. Pershing has appointed a third-party service provider IntraFi Network LLC (“IntraFi” or
“Administrator”), BNY Mellon Securities Corporation (“BNYSC”) and Dreyfus to provide certain services with
respect to the operation of the Deposit Accounts. MIC is a registered investment adviser and BNYSC is a broker-
dealer. BNY Mellon Investment Adviser, Inc. (“BNYIA” or “Adviser”) acts as investment adviser for the
Dreyfus Money Fund Sweep Products. Affiliates of BNY include but are not limited to, Pershing, BNYSC, MIC,
BNYIA, and BNY Mellon, N.A. BNY Mellon is the corporate brand for The Bank of New York Mellon
Corporation. For the most up-to-date information, see the applicable product-specific disclosure for a list of
BNY Mellon affiliates and their role in the operation of the Sweep Products.
Depending upon your account type, Lincoln Investment will designate a Sweep Product for use in your account.
Lincoln Investment offers two Bank Deposit Sweep Programs, the Dreyfus Insured Deposits L (“Tiered Rate
Sweep Product”) and the Dreyfus Insured Deposits LV (“Level Fee Sweep Product”), and two Money Fund
Sweep Products, the Dreyfus Government Cash Management Fund Service Shares Sweep Product (Ticker
symbol DGUXX) and the Dreyfus Government Cash Management Fund Investor Shares Sweep Product (Ticker
symbol DGVXX). Each of these Sweep Products except for the Dreyfus Government Cash Management Fund
Investor Shares, offered only to ERISA accounts and as the secondary Sweep Product for balances over
$2,490,000 in the Level Fee Sweep Product, creates financial benefits and conflicts for us as described below.
Lincoln Investment has designated the Dreyfus Government Cash Management Fund Service Shares for non-
ERISA 403(b)7 and 457(b) plans and participant accounts and as the secondary Sweep Product for balances in
excess of $2,490,000 in the Tiered Rate Sweep Product. Lincoln Investment has designated the Tiered Rate
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Sweep Product for use in commission-based individual retirement accounts (IRAs) and most non-retirement
brokerage and advisory accounts, and has designated the Level Fee Sweep Product for use in advisory IRAs.
Lincoln Investment receives a portion of the fee paid to Pershing by the Program Banks in connection with the
Bank Deposit Sweep Products and receives distribution assistance payments from Pershing in connection with
the Dreyfus Government Cash Management Fund Service Shares Sweep Product. Accordingly, Lincoln
Investment has a conflict of interest in that we have a financial incentive to designate the Tiered Rate Sweep
Product, the Level Fee Sweep Product and/or the Dreyfus Government Cash Management Fund Service Shares
Sweep Product as the Sweep Product(s) for your account and, for discretionary advisory programs managed by
Lincoln Investment, Lincoln Investment can allocate a portion of assets to the Sweep Product, each of which
generates additional revenue to us. This compensation is a significant source of revenue for Lincoln Investment
and Pershing. Pershing, other financial services firms and third parties could offer the same or similar money
market mutual fund sweep products and/or bank deposit sweep products, at a lower overall cost and higher
return to the investor than is available through the Sweep Program, whether directly through the provider or
through a sweep program offered by a different financial services firm. This receipt of revenue sharing from
Pershing creates a conflict of interest to Lincoln Investment to use Pershing as a custodian over other custodians
that do not share these fees, do not share these payments or that would share lesser amounts or that would not
permit us to set our own fee, to offer the Sweep Products and to recommend that you utilize the Sweep Products.
Lincoln Investment receives a greater financial benefit when cash is swept into the above Bank Deposit Sweep
Products and Money Fund Sweep Product than it otherwise would if your cash balance is held elsewhere, and
any compensation the firm receives reduces the interest and/or dividend you receive, and your overall investment
return. This compensation is retained by the firm and is not shared with you. Lincoln Investment receives greater
compensation as assets and/or accounts utilizing the Sweep Products increase, as more fully described below.
The Sweep Product fees that we receive are in addition to any investment advisory fees that you pay to Lincoln
Investment and your Advisor. This means that Lincoln Investment earns two layers of fees on the same Sweep
Product balances in your account, which can result in you experiencing a negative overall investment return. We
also receive different fees based on the Sweep Product designated for your account. Therefore, we have an
incentive for you to use (and invest your assets in) the sweep products that increase our compensation. If you
desire to maintain a cash balance in your account for an extended period of time awaiting investment and/or seek
the highest yields currently available in the market for your cash balance, please contact your Advisor or Lincoln
Investment for options outside of the Sweep Products. In order to mitigate these conflicts, Lincoln Investment
does not share this revenue with your Advisor. Your Advisor has the ability to waive the advisory fee on all
Sweep Products, should you request it.
Lincoln Investment has designated the Tiered Rate Sweep Product for use in commission-based IRAs and most
non-retirement brokerage and advisory accounts, and has designated the Level Fee Sweep Product for use in
advisory IRAs. Bank Deposit Sweep Products are an important source of significant revenue for Lincoln
Investment, Pershing, and Pershing’s affiliated Program Banks that participate in the Sweep Program. For
additional information regarding Pershing’s and their affiliates’ conflicts of interest, please see the link to our
Disclosures web page, included below. Lincoln Investment receives a portion of the fee paid to Pershing by the
Program Banks. Lincoln Investment sets the amount of the fee it receives from Pershing on your Bank Deposit
Sweep Product accounts and/or assets. This is a conflict of interest as it permits Lincoln Investment to assess a
higher fee to you in order to increase our revenue. Pershing offers other sweep products for which no
remuneration or less remuneration would be paid to Lincoln Investment, as introducing broker-dealer. The
portion of the fee received by us on the Bank Deposit Sweep Products is greater than the yield that you will
receive. Amounts paid to Lincoln Investment, Pershing and the Administrator reduce the interest rate paid on
your Bank Deposit Sweep Product balance. Therefore, the higher the compensation paid to us, the lower the
interest paid to you; the lower the compensation paid to us, the higher the interest paid to you. You should
understand that this can result in you experiencing a negative overall investment return with respect to your
balance in the Bank Deposit Sweep Product. Additionally, bank deposit sweep products typically yield lower
returns than money market mutual funds. However, because Lincoln Investment earns a higher fee when you
invest in Bank Deposit Sweep Products than if you invest in other money market products such as money market
mutual funds, within or outside of the Sweep Program, Lincoln Investment is incentivized to designate Bank
Deposit Sweep Products for your account(s). Lincoln Investment receives greater compensation related to Bank
Deposit Sweep Products as the amount of assets and/or accounts utilizing the Sweep Products increase and can
take up to 6.00% of the interest rate paid on the balances of your Deposit Accounts. For additional information
on Lincoln Investment’s current fees and compensation earned in relation to the Sweep Program, see the link to
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our Disclosures web page, included below. Accordingly, these arrangements present a conflict of interest to
Lincoln Investment because they provide an incentive for us to offer the Bank Deposit Sweep Products as our
default sweep products, to maintain balances in the Bank Deposit Sweep Products over other investment options,
including money market mutual funds, and for us and your Advisor to recommend that you enroll in and utilize
the Bank Deposit Sweep Products. For Bank Deposit Sweep Products balances in excess of $2,490,000, Lincoln
Investment has designated a secondary Money Market Sweep Product. For the Tiered Rate Sweep Product, the
secondary Money Market Sweep Product is Dreyfus Government Cash Management Fund Service Shares
(Ticker symbol DGUXX). If your excess balance is swept into Dreyfus Government Cash Management Fund
Service Shares, Lincoln Investment will earn fees on that balance, as further discussed below. For the Level Fee
Sweep Product, the secondary Money Market Sweep Product is Dreyfus Government Cash Management Fund
Investor Shares (Ticker symbol DGVXX). For additional information regarding these secondary Sweep
Products, please see the link to our Disclosures web page, included below. Program Banks do not have a duty to
offer the highest rates available or rates that are comparable to money market mutual funds or those offered by
other depository institutions or deposits held at Program Banks outside of the Sweep Program. The receipt of
revenue sharing from Pershing and the ability for Lincoln Investment to set its fee for the Sweep Products
creates a conflict of interest for Lincoln Investment to use Pershing as a custodian and to offer the Bank Deposit
Sweep Products we make available to you over other custodians or sweep products that do not pay a portion of
their fees to us (share revenue), share lesser amounts, or that do not permit the introducing broker-dealer to set
the fee it will assess for the Sweep Products.
Lincoln Investment has designated the Dreyfus Government Cash Management Fund Service Shares for non-
ERISA 403(b)7 and 457(b) plans and participant accounts and as the secondary Sweep Product for balances in
excess of $2,490,000 in the Tiered Rate Sweep Product, and Dreyfus Government Cash Management Fund
Investor Shares Sweep Product for ERISA accounts and as the secondary Sweep Product for balances in excess
of $2,490,000 in the Level Fee Sweep Product.
A Money Fund Sweep Product earns dividends, interest and other income from its investment, and distributes
this income (less expenses) to shareholders as dividends. For the Dreyfus Government Cash Management Fund
Service Shares Sweep Product, Lincoln Investment utilizes a share class that provides remuneration to us
(distribution assistance) which reduces the dividend you receive, even though other share classes are available to
Lincoln Investment that would pay Lincoln Investment less and you more. Lincoln Investment receives
distribution assistance from Pershing in the form of annual compensation of up to 0.55% for assets in the
Dreyfus Government Cash Management Fund Service Shares Sweep Product. This is not the least expensive
share class of the Dreyfus Government Cash Management Fund available or the least expensive share class
available through Pershing. Lincoln Investment utilizes a higher expense share class over other less expensive
share classes that would otherwise be available and of lower cost to you. There are less expensive share classes
of the same money market mutual fund available that would not provide revenue sharing with Lincoln
Investment or would provide lesser amounts of revenue sharing to us. Share classes with higher expenses can
lower your returns over time. This receipt of revenue sharing from Pershing creates a conflict of interest to
Lincoln Investment to use Pershing as a custodian and share classes offered by Pershing that provide
remuneration over other custodians and share classes that do not share these fees or payments, or that would
share lesser amounts, to offer the Sweep Products and to recommend that you utilize and maintain a greater
balance in the Sweep Products. Pershing offers other sweep products for which no remuneration or less
remuneration would be paid to Lincoln Investment, as introducing broker-dealer. The investment adviser to
Dreyfus Government Cash Management Fund Services Shares is BNYIA. BNYIA has engaged its affiliate,
Dreyfus, a division of Mellon Investments Corporation, to serve as the sub-investment adviser for Dreyfus
Government Cash Management Fund Services Shares. Lincoln Investment has an incentive to offer/recommend
Dreyfus Government Cash Management Fund Services Shares due to its agreement with Pershing which
incentivizes us to offer Pershing or its affiliates’ products so that we may share in a portion of the revenue.
The Dreyfus Government Cash Management Fund Investor Shares Sweep Product, for which no distribution
assistance is received by Lincoln Investment, is available only to ERISA accounts and as the secondary Sweep
Product for balances in excess of $2,490,000 in the Level Fee Sweep Product.
As previously indicated, certain Program Banks as well as Sweep Products affiliated with Pershing are made
available within the Sweep Program. Due to Lincoln Investment’s custodial and clearing arrangement with
Pershing, this creates a conflict of interest for Lincoln Investment because it provides an incentive for us to offer
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a Sweep Product and to recommend utilizing the Sweep Product so that Pershing receives additional
compensation and shares it with us.
For additional information and clarity regarding all Sweep Products offered including the designated Sweep
Product and secondary Sweep Product for your account, eligibility criteria, as well as applicable fees, rates, bank
lists, and conflicts of interest, please carefully review our Sweep Program disclosures, available on our public
website under our Disclosures section or at https://www.lincolninvestment.com/Disclosures. Please refer to The
Lincoln Investment Companies Sweep Program General Terms and Conditions to access the applicable money
market mutual fund prospectus.
In aggregate, the third-party payments and revenue sharing from Pershing to Lincoln Investment attributable to
Lincoln Investment advisory accounts in 2025 described above represented approximately seven percent of Lincoln
Investment’s total advisory revenue in 2025. The receipt of these third-party payments and expense credits create a
conflict of interest to Lincoln Investment to use Pershing as a custodian over other custodians that do not share these
fees, do not provide expense credits or that would share lesser amounts. Lincoln Investment mitigates these conflicts
by disclosing them to you and not sharing these payments/credits with your Advisor.
Other Conflicts and Potential Conflicts Related to Our Relationship to Pershing and its Affiliates
Trade Administration Fee Reduction. Lincoln Investment pays Pershing a fee based upon the amount of assets
in advisory programs for which Pershing provides trade administration services for Lincoln Investment advisory
accounts (“Trade Administration Fee”). Pursuant to written agreements with Pershing and BNYMA, Lincoln
Investment is eligible for an approximate 34% reduction in the Trade Administration Fee, contingent upon
attainment and maintenance of agreed upon asset levels invested in certain BNY affiliated products or services
by Lincoln Investment and its affiliate, Capital Analysts. Clients do not directly benefit from this expense
reduction. Lincoln Investment’s eligibility for this expense reduction creates a conflict of interest to Lincoln
Investment and its affiliate, Capital Analysts, to recommend and/or use Pershing as a custodian and/or trade
administrator and certain BNY affiliated products or services over other custodians, trade administrators or
products/services that do not provide for expense reductions or that would provide for lesser reductions to us.
BNY affiliated products include but are not limited to certain BNY affiliated mutual funds and ETFs.
Additionally, under our agreements with Pershing and BNYMA, Lincoln Investment and/or Capital Analysts
must continue to meet or surpass the agreed upon asset levels invested in certain BNY affiliated products or
services in order to continue to receive the reduction in Trade Administration Fee. Therefore, Lincoln Investment
and its affiliate, Capital Analysts, have an incentive to continue to meet or surpass the agreed upon asset levels
invested in certain BNY affiliated products or services.
BNYMA Overlay Fee Reduction. Lincoln Investment pays BNYMA a fee based upon the amount of assets in
advisory accounts where BNYMA acts as Overlay Manager (“Overlay Fee”). Pursuant to written agreements
with Pershing and BNYMA, Lincoln Investment is eligible for up to a 40% reduction in the Overlay Fee,
contingent upon attainment and maintenance of agreed upon asset levels invested in certain BNY affiliated
products or services by Lincoln Investment and its affiliate, Capital Analysts. Clients do not directly benefit from
this expense reduction. Lincoln Investment’s eligibility for these expense reductions creates a conflict of interest
to Lincoln Investment and its affiliate, Capital Analysts, to recommend and/or use Pershing as a custodian,
BNYMA as Overlay Manager and certain BNY affiliated products or services over other custodians, overlay
managers or products/services that do not provide for expense reductions or that would provide for lesser
reductions to us. BNY affiliated products include but are not limited to certain BNY affiliated mutual funds and
ETFs. Additionally, under our agreements with Pershing and BNYMA, Lincoln Investment and/or Capital
Analysts must continue to meet or surpass the agreed upon asset levels invested in certain BNY affiliated
products or services in order to continue to receive this expense reduction. Therefore, Lincoln Investment and its
affiliate, Capital Analysts, have an incentive to continue to meet or surpass the agreed upon asset levels invested
in certain BNY affiliated products or services.
Mutual Fund Surcharge Fee Waiver. Lincoln Investment has agreed to pay Pershing a surcharge fee for
transactions in certain mutual fund share classes in Lincoln Investment advisory programs. Pursuant to written
agreements with Pershing and BNYMA, Lincoln Investment is eligible for a waiver of surcharge fees for
transactions in certain advisory programs traded by Pershing/BNYMA, continual application of which is
contingent upon attainment and maintenance of agreed upon asset levels invested in certain BNY affiliated
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products or services by Lincoln Investment and its affiliate, Capital Analysts. Clients do not directly benefit from
this waiver. Lincoln Investment’s eligibility for this waiver creates a conflict of interest to Lincoln Investment
and its affiliate, Capital Analysts, to recommend and/or use Pershing as a custodian, BNYMA as Overlay
Manager and/or Pershing as trade administrator, and certain BNY affiliated products or services over other
custodians, overlay managers/trade administrators or products/services that do not provide for mutual fund
surcharge fee waivers or that would provide for lesser waivers. BNY affiliated products include but are not
limited to certain BNY affiliated mutual funds and ETFs. Additionally, under our agreements with Pershing and
BNYMA, Lincoln Investment and/or Capital Analysts must continue to meet or surpass the agreed upon asset
levels invested in certain BNY affiliated products or services in order to continue to receive these surcharge fee
waivers. Therefore, Lincoln Investment and its affiliate, Capital Analysts, have an incentive to continue to meet
or surpass the agreed upon asset levels invested in certain BNY affiliated products or services.
Pursuant to a written agreement, Lincoln Investment is obligated to provide certain providers/custodians, such as
Pershing and its affiliates, including BNYMA, the opportunity to participate in Lincoln Investment’s conferences or
events, without the separate payment of sponsor or registration fees. The ability to participate in such events
provides Pershing, BNYMA and its affiliates the opportunity to promote their affiliated products and services to
Lincoln Investment, its affiliate Capital Analysts and our Advisors. Increased use of BNY affiliated products and
services by Advisors of the firm will benefit the firm by assisting us with meeting the asset levels required for us to
receive a reduction/waiver in certain Pershing/BNYMA expenses. Platforms/custodians, including
Pershing/BNYMA, can waive or negotiate their respective fees assessed to you, Lincoln Investment and/or its
affiliates, and/or your Advisor, in each platform/custodian's sole discretion. Lincoln Investment and/or its affiliates
are not required to pass the waiver/reduction in cost along to you. We recognize these as conflicts for Lincoln
Investment and its affiliate, Capital Analysts, and mitigate these conflicts by disclosing them to you.
Sales & Marketing Support Revenue
Lincoln Investment receives Sales and Marketing Support as described below and includes Flat Fee Sponsors, Other
Sales Support and Asset and Sales Based Sponsors (collectively, “Sales and Marketing Support”). In order to
minimize the conflicts associated with the receipt of these fees, Lincoln Investment does not receive Flat Fee
Sponsor and Other Sales Support payments that are based on the amount of advisory account assets or advisory
account transactions with a particular sponsor, or that are based on ERISA advisory account assets. However, Flat
Fee and Other Sales Support Sponsors can compensate Lincoln Investment from assets of the mutual fund, the
fund’s investment adviser, distributor or other fund affiliate’s assets. While payments out of the fund's investment
adviser, distributor or other fund affiliate's revenues or profits are not directly paid from the fund's assets, fund
affiliate revenues or profits can, in part, be derived from fees earned for services provided to and paid for by the
fund. Payments out of fund assets can lower investor returns and performance over time. Lincoln Investment can
also receive Shareholder Services Fees from the same fund families and investment advisers that provide Sales and
Marketing Support. These sources of payments are a conflict of interest to Lincoln Investment to recommend and
promote those funds, fund families, investment advisers, distributors or other fund affiliates over others that do not
provide Sales and Marketing Support or that provide lower amounts of Sales and Marketing Support.
Flat Fee Sponsors. Lincoln Investment has partnered with a select group of third-party money managers and
product sponsors who pay to assist Lincoln Investment in the training and education of and outreach to Lincoln
Investment’s Advisors, at Lincoln Investment sponsored events, on such topics as advisory products and
services, practice management, tools and technology, consumer education, and policies, rules and regulations.
Additional opportunities can include but are not limited to attendance at and support of recognition club events,
exhibit booths, advisor presentations, seminars, mailings and publications. These sponsors provide financial
support to Lincoln Investment in the form of a flat-dollar amount that may be amended annually and is not based
on the sales of their proprietary products or services. Sponsors can compensate us from fund assets, the fund’s
investment adviser, distributor or other affiliate’s assets. Payments made out of fund assets can lower investor
returns and performance over time. Advisors do not share in any portion of these payments so as to mitigate any
conflict for an Advisor to recommend one product or money manager over another. This financial support allows
Lincoln Investment to defray or offset costs associated with Lincoln Investment sponsored events and other
educational and outreach tools and services. The financial support by these Sponsors to Lincoln Investment
presents a conflict of interest.
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All Flat Fee Sponsors do not pay Lincoln Investment the same amount, and depending on the amount of the
payment from the Flat Fee Sponsor, the access to Lincoln Investment sponsored events can differ. For example,
Lincoln Investment holds a number of sales conferences both nationally and regionally throughout the year to
educate advisors. The higher the annual flat fee payment, the more events the Flat Fee Sponsor will be invited to
attend. Flat Fee Sponsors have more opportunities than other product sponsors and money managers that are not
Flat Fee Sponsors to market to and educate Advisors, which could pose a conflict to Advisors to offer these
sponsors’ products or services over others. Advisors do not share in any portion of these payments so as to
mitigate any such conflict.
In 2025, the financial support from Flat Fee Sponsors paid to Lincoln Investment, as allocated across all
investment advisory assets with Lincoln Investment Planning, LLC and its affiliate, Capital Analysts, LLC did
not exceed one percent of total revenue for either of the affiliated registered investment advisers and in aggregate
was less than one percent of the combined revenue for both affiliated registered investment advisers. We do not
believe that these revenues are material. In 2025, Flat Fee Sponsors who compensated Lincoln Investment with a
flat fee payment, and offer a fund or advisory program that could be used in your advisory account, in order from
highest to lowest payment were Russell Investments, Clark Capital Management, AAMA, American Funds,
PIMCO Funds, Meeder Funds, Security Benefit Life, Nationwide, Transamerica Life, Federated Investors, BNY
Mellon, and Doubleline.
Some of the Flat Fee Sponsor revenue is used by Lincoln Investment to support the ongoing operational
expenses of Lincoln Investment, and its affiliates, and not used solely for sales and marketing support.
Other Sales Support. From time to time, product sponsors and third-party money managers assist Advisors in
their sales and marketing efforts by subsidizing certain Advisor costs, such as client meetings or workshops,
mailings, administrative expenses and technology support. The amount received from any one product sponsor
or third-party money manager in 2025 did not exceed $35,000. The sales support presents a conflict of interest in
that it could incentivize an Advisor to offer one product or money manager over another that does not provide
these subsidies or provides lesser amounts. To mitigate the conflict of interest presented by these payments and
subsidies, the amount is approved by Lincoln Investment and is monitored to ensure that it is not too frequent or
excessive. Also, Advisors are invited from time-to-time by product sponsors to due diligence and educational
meetings or seminars hosted by the product sponsor or money manager. This presents a conflict of interest that
could incentivize an Advisor to offer one product or money manager over another that does not offer these
meetings or seminars. Lincoln Investment must grant permission to our Advisors to attend any meeting or
seminar hosted by a product or advisory service sponsor. Lincoln Investment approves events that are limited to
education or due diligence only and allows the product sponsor to provide meals, hotel accommodations and
reimbursement to the Advisor, through Lincoln Investment, for travel expenses only. The education of our
Advisors in the offerings that are available to them is a key component of providing prudent investment advice
to you.
Ancillary Sales & Marketing Support Revenue paid to Lincoln Investment that is not tied to your Advisory
assets, or the platform where your Advisory assets are held, but is tied to the Non-Advisory assets or
transactions in which you may invest
Asset and Sales Based Sponsors. In connection with non-investment advisory (non-fee-based) assets of our
investors, and in addition to the compensation described above, Lincoln Investment receives Sales and
Marketing support from product sponsors, mutual fund companies, insurance companies and other third-party
providers to assist in the marketing and sales efforts of employees and Advisors (“Asset and Sales Based
Sponsors”). Asset and Sales Based Sponsors have the opportunity to educate and train employees and Advisors
with respect to investment products and services, practice management, tools and technology, consumer
education, and policies, rules and regulations. Additional opportunities can include but are not limited to
attendance at and support of recognition club events, exhibit booths, advisor presentations, seminars, mailings
and publications. The support provided by these sponsors is based on brokerage-only (non-investment advisory)
assets and brokerage transactions and not based on your advisory account assets or ERISA advisory assets. We
receive compensation from these sponsors in various forms, including as a flat fee, a percentage of the amount of
brokerage assets held by investors, a percentage of sales, or any combination of these methods. The amounts of
these payments can vary by the type of product and by provider and can include, but are not limited to,
distribution fees and shareholder service fees. All Asset and Sales Based Sponsors do not pay Lincoln
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Investment the same amount, and depending on the amount of the payment, the access to Lincoln Investment
sponsored events and other opportunities can differ. The higher the payment, the greater the access for the Asset
and Sales Based Sponsor to attend events, participate in marketing and sales opportunities and interact with
Advisors. This presents a conflict of interest to Advisors to offer these sponsors’ products or services over
others. Advisors do not share in any portion of these payments so as to mitigate any such conflict. Additionally,
some Asset and Sales Based Sponsors make a monthly or quarterly payment or additional monthly or quarterly
payment based on the assets you hold in a fund or variable insurance product over a period of time. As you may
have both a brokerage account and an advisory account with us, we want you to understand that Lincoln
Investment will receive Sales and Marketing Support based on assets or sales in connection with your brokerage
account assets and transactions. The Asset and Sales Based Sponsors payments present a conflict of interest to
Lincoln Investment to recommend Asset and Sales Based Sponsors that provide sales and marketing support
over others that do not or that provide lesser amounts. Some of the Asset and Sales Based Sponsor revenue is
used by Lincoln Investment to support the ongoing operational expenses of Lincoln Investment, and its affiliates,
and not used solely for sales and marketing support.
The following is a list of Asset and Sales Based Sponsors in order of high to low total compensation paid to
Lincoln Investment as broker-dealer based on non-fee based account assets or sales in 2025: Security Benefit
Life, Franklin Templeton Group, Jackson National Life Ins Co, Allianz, Lincoln National Life, Athene,
Nationwide, AXA Equitable Life Insurance Company, Prudential, Brighthouse Financial, Pacific Life,
Transamerica Life, Mewbourne Development Corporation, Simplicity, the Standard, Pershing, Blue Rock
Capital, Voya Mutual Funds, and Meeder Funds. The Asset and Sales based Compensation in 2025 was less than
$3 million dollars from these product sponsors and represented less than one percent of the total revenues of
Lincoln Investment. We are disclosing this information to you as certain providers and products offered by the
providers shown above could be available within our investment advisory offerings.
Outside of the Sweep Program, Pershing, as clearing firm for accounts introduced by Lincoln Investment, shares
with Lincoln Investment a nominal amount of asset-based revenue it receives from certain mutual fund
companies in non-advisory accounts. As this revenue received from Pershing is non-advisory related and not
material, Lincoln Investment is disclosing the conflict that we receive this revenue rather than list each mutual
fund product that generated the compensation to the firm.
Other Conflicts and Potential Conflicts
Other financial services firms and third parties could offer advisory services, securities products, or insurance at a
lower overall cost to you than what is available through your Lincoln Investment account, or you could invest
directly with a provider.
Ongoing Fiduciary Conflicts. Lincoln Investment has a supervisory duty to periodically monitor clients’
portfolios to ensure suitability of investments and to ensure that the advisory services are being performed in
recognition of our fiduciary duty to you, which includes acting in your best interest. A conflict of interest exists
if an Advisor is assessing an advisory fee but no services are being performed. Supervision is performed over
accounts and Advisors to monitor for activities that could be deemed a breach of our fiduciary duty to you,
including such periodic reviews as accounts where there is no documentation of services being performed and
accounts with uninvested cash balances over a 12-month period of time with no rationale for holding such a
large cash position in an advisory account. In an advisory relationship, our fiduciary relationship will be most
successful if both the client and the Advisor partner to ensure that there is regular and meaningful contact and
that the advisory account continues to meet the needs of the client.
Lincoln Investment’s Other Businesses. Lincoln Investment’s principal business is as an investment adviser.
The majority of Lincoln Investment’s revenue comes from the advisory fees we collect from you. As a broker-
dealer, Lincoln Investment also receives compensation from its brokerage business. This compensation comes
from securities and insurance product commissions and mutual fund concessions, 12b-1 distribution fees
associated with the sale of mutual funds, shareholder service fees, reallowances, trailing commissions from
annuity sales and persistency bonuses on insurance and other sources. Lincoln Investment, acting as both a
broker-dealer and registered investment adviser, could be deemed a conflict of interest. This places an additional
responsibility on Lincoln Investment to supervise whether a recommendation to open either an advisory account
or a commissionable account, or both, is appropriate. You always have the option to purchase advisory services,
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securities products or insurance through non-affiliated investment advisers, brokers or agents. Lincoln
Investment also is affiliated with Capital Analysts, LLC, an SEC registered investment adviser, and promotes the
services of this investment adviser.
Your Advisor’s Other Businesses. Your Advisor can have more than one relationship with you. Your Advisor
acts as an investment adviser representative when he or she provides advisory services to your account and earns
advisory fees based on your assets under management/advisement, and/or when he or she provides planning
services to you and earns a flat or hourly fee. Your Advisor acts as a registered representative/agent when he or
she makes recommendations to you for your non-advisory account where he or she receives a sales commission
for the sale of securities or insurance products, which would be in addition to any advisory fees earned in your
advisory account. In these situations, your Advisor may have greater financial incentives to offer you both
investment and/or insurance sales as well as advisory services. In addition, if a planning services client chooses
to implement any planning recommendations, your Advisor may have greater financial incentives to offer you
both investment and/or insurance sales as well as advisory services.
Your Advisor can also be associated with Lincoln Investment’s affiliated investment adviser, Capital Analysts,
LLC. These affiliated relationships present a conflict of interest. Through his or her affiliation with Lincoln
Investment and possibly with Capital Analysts, your Advisor is in a position where he or she can offer the same
or similar advisory services to you for different fees and compensation structures. If an identical Sub-Adviser,
third-party manager or strategy is available through two affiliated registered investment advisers, you could pay
higher fees for an advisory service that is similarly offered through another affiliated investment adviser. You
always have the option to purchase advisory services, securities products or insurance through non-affiliated
investment advisers, brokers or agents.
Lincoln Investment pays out to each Advisor a specified percentage of the Advisor’s fee. This percentage varies
by Advisor based on such factors as Advisor experience, type of contract the Advisor has with the firm, amount
of investor assets with the firm, type of advisory service, categories of products and the amount of investor assets
managed by the IM&R Team. These varying payout rates create a conflict of interest for your Advisor to
recommend certain services and categories of products, including advisory services managed by the IM&R
Team and your Advisor, over others with a lower payout rate. Lincoln Investment can pay compensation,
including bonus payments, to Advisors who agree to engage in mentorship of another financial professional.
Most of Lincoln Investment’s Advisors are independent contractors who may also offer other non-security
financial services and products, such as life, health, disability, long-term care and fixed annuity insurance
products, and real estate. These services may be offered independent of The Lincoln Investment Companies.
Security recommendations may be limited to products offered by the broker-dealer. Although a client always has
the ability to purchase security products through other broker-dealers, the fee schedule for services described
herein may have been structured with the understanding that clients will implement financial product
recommendations through the Advisor. You are under no obligation to implement, in whole or in part, any
recommendation, advice or suggestion made by your Advisor. You may take any such recommendation, advice
or suggestion available from any other professional retained by you to assist in the implementation of the
planning services. If you choose to implement your Advisor’s recommendations and open an investment
advisory account or add an additional service through Lincoln Investment and/or Capital Analysts, then, prior to
making the decision to implement, you should read Lincoln Investment’s and/or Capital Analysts’ Investment
Advisory Disclosure Brochure and Wrap Fee Brochure for a description of conflicts and potential conflicts of
interest that we have identified in the conduct of our business that we believe may be material to any
recommendations when implemented through us.
Sales Contests. Lincoln Investment offers sales contests based on such criteria as gross compensation to the
Advisor, new accounts, new investors, initiation of periodic contributions, total fee-based assets and net sales of
fee-based programs. These contests can provide your Advisor with a conflict of interest and an incentive to offer
you fee-based advisory services over commission-based brokerage services, offer you advisory services
managed by the IM&R Team and your Advisor over third-party advisory services and to conduct additional
business in order to be eligible. Top achievers in these contests are eligible to receive Lincoln Investment-
sponsored trips, awards, cash prizes, bonus commissions, bonus payments, club points, monetary donations in
their name to a charity of their choice or other nominal prizes subject to applicable law. To mitigate the conflicts
of interest presented by these incentives, no contest is offered which will award the Advisor based upon a
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specific investment product or on a specific third-party product sponsor. Brokerage commissions and brokerage
assets associated with Massachusetts residents are excluded from Lincoln Investment’s sales contests consistent
with applicable state law. For Massachusetts’ residents, this creates a financial incentive for your Advisor to
recommend advisory services over brokerage services. Lincoln Investment mitigates these conflicts by
disclosing them to you and supervising the investment advisory activities and brokerage practices of its
Advisors. In our capacity as an investment adviser, Lincoln Investment and its Advisors recognize they have a
fiduciary duty to investment advisory clients. Although Lincoln Investment does not offer specific product sales
incentives for securities products, issuers of non-securities insurance products, such as fixed annuity issuers, may
offer sales incentives to Advisors in the form of cash bonuses and trips if certain sales thresholds are met. You
should ask your Advisor about these incentives at the time of sale.
Other Asset Level Payments (Available to Certain Advisors). Certain Advisors are eligible to receive,
directly or indirectly, additional compensation from Lincoln Investment when specified thresholds of total assets
are met by that Advisor and other Advisors with whom they are associated (“Other Asset Payment” or “OAP”).
OAP creates a conflict of interest for the Advisor to recommend certain offerings, including advisory services
managed by the IM&R Team and the Advisor, over others for which they would not receive additional
compensation in the form of OAP. These payments to your Advisor directly or indirectly would result in your
Advisor receiving greater compensation than what is indicated as the Financial Advisor Fee in your investment
advisory agreement. The payment of OAP to an Advisor, including your Advisor, has no impact on the total
client fee paid by you for the selected offering. These payments also create a conflict of interest for Lincoln
Investment to compensate Advisors in order to maintain or increase assets managed by the IM&R Team and the
Advisor, over other advisory services or platforms where Lincoln Investment receives less revenue. Lincoln
Investment mitigates these conflicts by disclosing them to you and supervising the investment advisory activities
and brokerage practices of its Advisors.
Payments to Employers and Organizations Associated with an Employer who Sponsor Non-ERISA Plans.
Lincoln Investment has contracts with employers to enable employees who work for these employers to open
and invest in a primary or supplemental retirement account through payroll deduction contributions through an
account with us. The majority of employers with whom Lincoln Investment has contracts offer non-ERISA
403(b) and 457(b) retirement plans to their employees. Also, many of these employers are school districts and
the employees are teachers or other eligible employees. Lincoln Investment and our Advisors make contributions
from time-to-time to organizations that are associated with an employer, such as administrators and teachers’
associations, consultants, non-profits, and scholarship or grant funds. Lincoln Investment and our Advisors can
also sponsor a business or social event, conference, meeting, fundraiser or scholarship by making a monetary
contribution or by providing nominal supplies to assist the employer and/or their employees.
Third Party Administrator (TPA) Payments. TPAs that provide administrative services to the employer charge
the employer an annual per participant retirement plan administration fee for their services. Certain TPAs and/or
employers list Lincoln Investment as an investment provider (along with other providers) and we have agreed to
pay the per-participant TPA fee for a participant who opens or holds an account with us. This reduces the cost to
the employer sponsor of the retirement plan and/or the participant.
Exclusive Provider. Less than one percent of our employer contracts are an exclusive arrangement where
Lincoln Investment is the only provider who has been authorized to work with the employees to establish a
primary/supplemental retirement plan account. You can ask your Advisor whether Lincoln Investment has an
exclusive arrangement with your employer.
Other Non-Exclusive Provider Payments. In order to be a 403(b) provider/vendor in California,
providers/vendors must register with 403bCompare, a program of the California State Teachers’ Retirement
System (“CalSTRS”). Lincoln Investment is registered with 403bCompare and pays an annual 403(b)
provider/vendor fee as determined and assessed by CalSTRS. The total fee assessed to all providers/vendors
covers the cost to administer and maintain the 403bCompare.com website.
The payments and benefits described in this section create a conflict of interest to the employer and employees
since they could serve as an incentive to select the products and services of Lincoln Investment and its affiliates
over other providers that do not make these payments or pay lesser amounts. We mitigate these conflicts by
disclosing them to you and avoiding payments that we consider too frequent or excessive.
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Loans, Advances and Other Benefits. Lincoln Investment can extend loans, provide bonuses and other
benefits, provide commission/fee advances, and pay for practice management services for an Advisor to assist
the Advisor in transitioning to the firm, and/or maintaining or expanding his or her business. Lincoln Investment
does not verify that any payments made are used for these purposes. Sometimes the availability and amount of
loans and advances are conditioned upon, are forgiven (waived) or reduced, in whole or in part, interest rates
reduced, and/or bonuses provided if an Advisor remains affiliated with the firm or achieves certain sales or
assets under management thresholds, revenue targets, production levels, asset additions, new client goals, client
retention goals, recruiting goals and certain practice management goals or conditions, individually or with other
Advisors. These practices present a conflict of interest in that the Advisor has a financial incentive to affiliate
with and remain affiliated with the firm during the repayment period in order to receive these benefits over other
firms that do not offer these incentives or offer a similar level of incentives. These practices also present a
conflict in that the Advisor has a financial incentive to generate more business or to recruit other financial
professionals to generate more business, and achieve certain sales, revenue, asset additions or asset management
thresholds in order to receive a loan or advance, increase the amount of the loan or advance, and/or satisfy or
reduce the amount of the loans or advances. The extent of the conflict can increase as your Advisor approaches
certain milestones. In situations where a sales, production, recruiting, revenue, asset additions, assets under
management threshold or other financial contingency exists, this conflict of interest will be disclosed in your
Advisor’s Form ADV 2B Supplement (“BIO Brochure”), which is required to be delivered by the Advisor to
every client. Lincoln Investment mitigates these conflicts by disclosing them to you and supervising the
investment advisory activities and brokerage practices of its Advisors.
Additionally, Lincoln Investment can extend a loan or advance to an Advisor for which repayment is required
which can create a conflict for the Advisor to generate more business in order to repay the loans or advances to
the firm during the repayment period. Additionally, some Advisors receive benefits as they transition to the firm
and/or for maintaining their business, which can include but is not limited to, technology services, administrative
support, licensing, insurance and administrative fees, the opportunity to participate in a unit appreciation rights
plan of an affiliate or parent of Lincoln Investment, and reimbursement of fees associated with transitioning
accounts. These practices present a conflict of interest in that the Advisor has a financial incentive to affiliate
with and remain affiliated with the firm over other firms that do not offer these incentives or offer a similar level
of incentives. Lincoln Investment mitigates these conflicts by disclosing them to you and supervising the
investment advisory activities and brokerage practices of its Advisors.
Advisor Referral Program. Lincoln Investment compensates Advisors and employees who have referred
another financial professional to the firm if that referred financial professional then decides to affiliate with
Lincoln Investment or an affiliate. This creates an incentive for Advisors and employees to affiliate with our firm
over others that do not offer similar compensation, and to refer financial professionals in order to receive this
compensation. We do not believe that this practice presents a material conflict of interest.
Gifts and Entertainment. Offering or receiving a gift or entertainment from a product or advisory service
sponsor could create a conflict of interest. Lincoln Investment has instituted a policy that prohibits excessive
and/or too frequent gifts or entertainment activities to mitigate this conflict.
Political Contributions. Providing significant political contributions to a state or local official or candidate
could create the perception that Lincoln Investment or its Advisors are seeking quid pro quo arrangements with
that state or local government or its employees to open an account with our firm. Lincoln Investment prohibits
contributions in excess of $350 per election if the Advisor can vote for the candidate and $150 per election if the
Advisor cannot vote for the candidate.
Charitable Donations. Providing significant charitable donations to a charity organization could create the
perception that Lincoln Investment or its Advisors are seeking quid pro quo arrangements with that charity or its
employees to open an account with our firm. Lincoln Investment allows contributions to charities but prohibits
any donations that are deemed excessive or too frequent.
Accounts Maintained on Institutional Platforms
The following applies to clients whose accounts are held at Schwab and Fidelity (“Institutional Platforms”).
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Lincoln Investment’s Advisors can recommend that clients establish brokerage accounts with one or more
Institutional Platforms to maintain custody of clients’ assets and to effect trades for their accounts. The final
decision to custody assets with an Institutional Platform is at the discretion of the Advisor’s clients, including
those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan
sponsor or IRA accountholder.
Products & Services Available to Us from Institutional Platforms
Institutional Platforms serve independent investment advisory firms like ours. They provide Lincoln
Investment and our clients with access to its institutional brokerage – trading, custody, reporting and related
services – many of which are not typically available to the Institutional Platform’s retail customers.
Institutional Platforms also make available various support services. Some of those services help us manage or
administer our clients’ accounts while others help us manage and grow our business. Institutional Platform
support services are generally available on an unsolicited basis and at no charge to us. Some institutions such
as Charles Schwab and Co., Inc. require we maintain a total of at least $10 million of our clients’ assets in
accounts at Schwab to avail ourselves of those services at no charge. These Institutional Platform providers
generally do not charge separately for custody services but are compensated by account holders through
commissions or other transaction-related or asset-based fees for securities trades that are executed through
them or that settle into their accounts.
Services that Benefit Clients
Institutional brokerage services include access to a broad range of investment products, execution of securities
transactions, and custody of client assets. The investment products available through Institutional Platforms
include some to which we might not otherwise have access or that would require a significantly higher
minimum initial investment by our clients. These services generally benefit clients or their account(s).
Services that May Not Directly Benefit Clients
Institutional Platforms also make available to us other products and services that benefit us but may not
directly benefit the client or their account(s). These products and services assist us in managing and
administering our clients’ accounts. They can include both their own investment research and that of third
parties. We can use this research to service all or some substantial number of our clients’ accounts, including
accounts not maintained at the Institutional Platform providing the services. In addition to investment research,
Institutional Platforms make available software and other technology that:
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provides access to client account data (such as duplicate trade confirmations and account statements);
facilitates trade execution and allocate aggregated trade orders for multiple client accounts;
provides pricing and other market data;
facilitates payment of our fees from our clients’ accounts; and
assists with back-office functions, recordkeeping and client reporting.
Institutional Platforms also offer other services intended to help us manage and further develop our business
enterprise. These services can include:
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educational conferences and events;
technology, compliance, legal, and business consulting;
publications and conferences on practice management and business succession; and
access to employee benefits providers, human capital consultants and insurance providers.
Institutional Platforms may provide some of these services. In other cases, they will arrange for third-party vendors
to provide the services. They can also discount or waive their fees for some of these services or pay all or a part of a
third party’s fees. While, as a fiduciary, Lincoln Investment endeavors to act in its clients’ best interests, Lincoln
Investment’s recommendation that clients maintain their assets in accounts at the Institutional Platform can be based
in part on the benefit to Lincoln Investment or its Advisors of the availability of some of the foregoing products and
services and other arrangements and not solely on the nature, cost or quality of custody and brokerage services
provided by these Institutional Platforms, which creates a conflict of interest.
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Item 6: Performance-Based Fees and Side-by-Side Management
Lincoln Investment and our Advisors do not receive performance-based fees. A performance-based fee is an
advisory fee that compensates the advisor for the advisor's success in managing his client's money or "a fee based on
the share of the capital gains and appreciation of a client's funds." A performance-based fee may induce an advisor
to take greater and undue risks with client's funds in an attempt to generate higher compensation to the advisor.
Your Advisory Fees with Lincoln Investment are typically assessed as a percentage of the total value of your
advisory account assets as of each month-end and are not performance-based fees.
Item 7: Types of Clients
Lincoln Investment primarily serves individuals, high net worth individuals, trusts, businesses, and charitable
organizations as well as the retirement assets of individuals and businesses, including, through IRC 403(b) and 457
programs, individual retirement accounts (“IRAs”) and employer sponsored ERISA plans. We also offer our
institutional investment advisory services to third-party investment advisers and trust companies. Clients may open
qualified and non-qualified accounts with Lincoln Investment. Not all investors and plans, including retirement
plans, are eligible to invest in one or more of Lincoln Investment's advisory programs. Please consult with your
Advisor or your employer to determine if your assets are eligible to invest.
Advisor managed accounts in the Client Custom Portfolios Program on the Lincoln Signature Solutions platform do
not require a minimum account size unless one is required by your Advisor; however, clients must meet the mutual
fund stated minimum to invest assets in a specific mutual fund. Accounts must meet a minimum account size or
minimum periodic investment to invest assets in a Lincoln Investment managed model portfolio. For specific
information related to minimum account size, see Item 4: Advisory Business. Lincoln Investment and sub-advisers
may, from time to time, amend or waive the minimum account size. Consult with your Advisor for more information
on minimum account size requirements.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Investing in securities involves risk of loss that you, the investor, should be prepared to bear.
The advisory services and advice offered by Lincoln Investment and its Advisors primarily attempt to provide to you
a risk-appropriate diversified portfolios comprised primarily of mutual funds. A risk-appropriate diversified
portfolio applies the disciplines and theories of asset allocation. Asset allocation means, first and foremost, working
to design a portfolio that sufficiently allocates your assets across different asset classes to help reduce the exposure
to any single asset class and market loss you could incur in your account(s) if you didn’t diversify. It is important to
understand that asset allocation, although a proven theory to reduce risk to a portfolio, does not guarantee a profit or
protect against loss. A diversified portfolio typically will not perform as well as a stock market index, such as the
S&P 500, in a rising market environment, and it will typically not decline as much in a declining market
environment.
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 commodities. Equities can
be further broken down by market capitalization (company size based on annual revenues) ranging from large
companies (large-cap) to medium and small companies (medium- 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 term.
Your Advisor will determine with you your risk profile and objectives, create an asset allocation policy, recommend
a risk appropriate well diversified portfolio, and may periodically re-balance the account back to any stated asset
allocation, if any, as may be permissible in your advisory program. Your Advisor will also periodically review your
account with you to determine if any additional changes should be recommended or made to your account. Your
Advisor can analyze your financial situation provided you make available to them your personal and financial data,
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employee benefit and retirement programs, business continuation plans and even your most recent estate planning
arrangements. The Advisor can coordinate with your attorney, accountant, and other staff to discuss solutions. If
your Advisor analyzes your investment portfolio, the security analysis methods may include charting, fundamental,
technical or cyclical analysis.
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. Each mutual fund will then be assigned by Lincoln Investment into one of the
asset classes identified above and the mutual funds that best meet Lincoln Investment's criteria for inclusion in our
Asset Management Programs will be selected. 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, described in more detail below.
Using a risk appropriate diversified portfolio, Lincoln Investment uses two approaches to further manage your
money in its asset management program advisory services: a Strategic approach and a Dynamic (or 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 within the designated risk tolerance. There is
typically no change in the asset classes within these model portfolios. Each portfolio manager can select
and replace different securities within those asset classes.
• Dynamic (also referred to as Tactical): A strategy that makes market trades in your portfolio in an
attempt to take advantage of potential market opportunities within the designated risk tolerance. There can
be changes in the asset classes and industry sectors within these model portfolios. Each portfolio manager
can vary the asset allocations within each model portfolio in an attempt to capture market opportunity.
For some offered asset management programs, management is provided by Lincoln Investment’s IM&R Team. For
other offered asset management programs, Lincoln Investment has engaged third-party asset managers (“Sub-
Advisers”) to manage portfolios in alignment with a stated objective, investment discipline and risk level. Each Sub-
Adviser appointed by Lincoln Investment offers a unique discipline to investing. Although the management
authorization of your account (if invested in an IM&R program) remains with Lincoln Investment, we oversee that
the Sub-Advisers manage to their assigned discipline and risk level.
In the Strategic Asset Management Programs managed in-house by the IM&R Team, the selection of mutual funds
for the asset management programs uses a quantitative approach that takes into consideration such factors as: current
style of the fund, style consistency, R-squared, as well as multiple performance factors and the expense ratio of the
fund. This quantitative approach is utilized to assist with management of model portfolios, including, but not limited
to, the following asset management programs: Dividend Income, Lincoln Strategic, Progressive Asset Management
and Progressive Asset Management ESG.
In the Dynamic asset management programs managed in-house by the IM&R Team, the team uses a mixture of tools
in the management of our discretionary Adaptive Intelligence Model (“AIM”) Asset Management Programs. Our
investment discipline incorporates research, quantitative and qualitative tools, and neural networks into portfolio
management decisions in an effort to highlight asset class absolute and/or relative strengths which can be
incorporated into portfolio management decisions. Any neural network tool associated with AIM is just one tool and
does not in and of itself make any investment decisions. A neural network is a computer system that uses
mathematical algorithms to simulate certain cognitive processes of a biological neural network, such as the human
brain. Neural networks sift through data, using user-defined parameters, to identify patterns which generate
directional information across multiple asset classes, and determine relative strengths of those asset classes. The
aforementioned tools or data outputs generated from these tools can be used individually, in concert with one or
multiple other tools, or not used at all, at the discretion of the Lincoln Investment Portfolio Manager, to assist with
management of model portfolios in the AIM programs.
For our risk-adjusted AIM model portfolios (such as Conservative Income, Conservative Growth & Income,
Balanced, Total Return, Appreciation, and Growth Portfolios), we may utilize one or more of the research materials
and quantitative and qualitative tools to make specific percentage allocation recommendations by asset class for
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each risk level model portfolio. These recommendations take into consideration the investment objective(s) and risk
tolerance of an AIM model portfolio when providing such asset class weightings. Lincoln Investment does not
employ risk tolerance constraints for all AIM advisory model portfolios in the same manner. The AIM Absolute
Return and Managed Income & Growth model portfolios generally do not have as stringent risk tolerance
constraints (i.e., there is little to no limitation as to the exposure your account will have to any given asset class).
In their investment decision-making process, the Lincoln Investment Portfolio Manager may use the aforementioned
tools, along with fundamental and technical analysis, to develop asset allocation recommendations for our dynamic
asset allocation model portfolios. Once asset allocation recommendations are developed, we utilize our Fund
Selector screening program to make quantitatively supported projections as to the mutual funds, exchange-traded
funds (“ETFs”), and variable annuity sub-accounts for insight on future market performance within each asset class.
The Fund Selector program uses variations of mathematical equations and proprietary formulas that assess the rate
of consistency for fund performance and risk measurements. Subjective qualitative methodologies may also be used
to identify and compensate for anomalies in the quantitative research. For example, if a fund has experienced a
managerial change in the past year, the Portfolio Manager may combine performance from the manager’s previous
fund to gain a broader perspective of their management skills.
There is no guarantee that the investment recommendations made by Lincoln Investment’s Portfolio Manager with
the assistance of research materials, quantitative and/or qualitative tools, or any of our other models in the future
will be accurate. These tools and others can be used or considered at the discretion of the Lincoln Investment
Portfolio Manager and they do not in and of themselves make any investment recommendations or decisions with
regard to management of the AIM model portfolios.
Lincoln Investment uses asset allocation and diversification in an attempt to achieve the objectives of our model
portfolios. Asset allocation involves allocating an investment portfolio among different asset classes, such as stocks,
bonds and cash. Our dynamic model portfolios are proactively reallocated to reflect changes in market expectations.
Diversification is the practice of spreading money among different investments to reduce risk.
For assets in one of the Lincoln Investment Managed Programs, Lincoln Investment may invest your assets in any
asset class we deem necessary in an effort to achieve a model portfolio’s objective. Such asset classes may include,
but are not limited to: large-capitalization domestic equities, mid-capitalization domestic equities, small-
capitalization domestic equities, high quality domestic debt, high yield domestic and foreign debt, international
equities, emerging markets equities, emerging markets debt, foreign debt, real estate investment trusts, real assets,
Treasury Inflation-Protected Securities, agency securities and Commercial Mortgage-Backed Securities and cash.
Investing in securities involves risk of loss that clients should be prepared to bear. Lincoln Investment cannot assure
that any portfolio will increase or preserve capital or generate income, nor can we assure that the objectives of any
model portfolio will be realized. Asset allocation decisions made by Lincoln Investment may result in a profit or
loss. As more investments are added to a portfolio, fees and expenses may increase, which will, in turn, lower
investment returns. Diversification does not assure a profit or protect against a loss. Mutual funds purchased for your
account may invest in different types of securities, such as value or growth stocks, real estate investment trusts,
corporate bonds or U.S. government bonds. There are risks associated with each asset class. Because each fund
within a portfolio owns different types of investments, portfolio performance will be affected by a variety of factors.
The value of your account will vary from day to day as the values of the underlying investments you hold vary. Such
variations generally reflect changes in interest rates, market conditions and other company and economic
news. These risks may become magnified depending on how much a fund invests or uses certain strategies.
The asset classes and types of investments used by Lincoln Investment and your Advisor in implementing the
methods of analysis and investment strategies described above carry material risks.
• Cash & Cash Equivalents: Lincoln Investment may invest a portion of your assets in cash or cash equivalents
to achieve a model portfolio’s objective, provide ongoing distributions and/or take a defensive position. Cash
holdings may result in a loss of market exposure. For discretionary advisory programs managed by Lincoln
Investment, Lincoln Investment allocates a portion of account assets to the Sweep Product or free credit
balance. See Other Compensation to Lincoln Investment and Our Conflicts of Interest for additional information
and conflicts applicable to The Lincoln Investment Companies Sweep Program.
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• Environmental, Social and Governance (ESG) Funds: Environmental, Social and Governance (“ESG”)
investing can be referred to in many different ways, such as sustainable investing, socially responsible
investing, and impact investing. ESG fund practices can include, but are not limited to, strategies that select
companies based on their stated commitment to one or more ESG factors (e.g., environmental, social and
governance) - for example, companies with policies aimed at minimizing their negative impact on the
environment or companies that focus on governance principles and transparency. Funds that elect to focus on
companies’ ESG practices may have broad discretion in how they apply ESG factors to their investment or
governance processes. An ESG fund portfolio might include securities selected in each of the three categories,
or in just one or two of the categories. A fund’s portfolio might also include securities that don’t fit any of the
ESG categories, particularly if it is a fund that considers other investment methodologies consistent with the
fund’s investment objectives.
In selecting funds for Lincoln Investment’s ESG model portfolios, Lincoln Investment can consider data from
third-party providers. This data could include “scoring” and “rating” data compiled to help managers, such as
Lincoln Investment, compare funds. Some of the data used to compile third-party ESG scores and ratings may
be subjective. Other data may be objective in principle, but are not verified or reliable. Lincoln Investment’s
Portfolio Manager will make the ultimate decision as to whether or not a fund is ESG for purposes of the ESG
model portfolios and whether or not a fund should be included in the ESG model portfolios. Lincoln
Investment’s ESG model portfolios can include funds that take a diversified ESG approach (e.g., funds that fit
two or three ESG categories) or funds that target a specific ESG category (e.g., funds that fit just one ESG
category). Our ESG model portfolios can also include mutual funds that do not have any ESG mandate.
Lincoln Investment’s ESG practices may significantly influence performance. Because funds may be included
or excluded based on ESG factors rather than other investment methodologies, Lincoln Investment’s ESG
model portfolio performance may differ (either higher or lower) from the overall market or comparable model
portfolios that do not employ similar ESG practices.
• Equities: The price of equities fluctuate due to many factors including changes in interest rates, global events,
industry and company specific events, investor expectations, and general market conditions. You can receive
more or less than the original purchase price when selling a security. Concentrated positions in equities
typically pose additional risks as a downturn in your investment will cause a more significant loss.
Diversification assists in reducing concentration risk. Equity mutual funds may include small, mid and large-
capitalization stocks. Small and mid-capitalization companies may have greater price volatility, lower trading
volume and less liquidity than large-capitalization companies.
• Exchange Traded Funds (ETFs): While investing in ETFs has similar risks as investing in individual equities,
ETFs typically invest in a diverse group of securities. The level of diversification varies by ETF. While ETFs
reduce the effects of concentration risk as compared to investing in a single security, certain ETFs are
susceptible to industry, commodity or country risk. Investing in a diverse selection of ETFs may help to reduce
this risk. Another important factor to consider with ETFs is that the portfolio of securities in which they invest
are typically not actively managed. Leveraged and Inverse ETFs bear unique risks that investors who wish to
trade in these securities must understand; due to the significant risk involved in these securities, Lincoln
Investment will approve their use only on an exception basis.
Buffer ETFs, also known as defined outcome ETFs, use options contracts to insure against some losses while
capturing some gains. The primary caveat with buffer ETFs is that, while they provide downside protection,
they also limit an asset’s returns. Additionally, buffer ETFs have slightly higher fees than traditional ETFs.
For example, a buffer ETF could hypothetically offer 50% protection against loss with a 7% upside cap. This
means that you are shielded from losses if the market drops by up to 50%, but, if the market goes up 20%, you
are still only entitled to a 7% return. A new cap is established at the beginning of each Target Outcome Period
and is dependent on prevailing market conditions. As a result, the cap may rise or fall from one Target Outcome
Period to the next and is unlikely to remain the same for consecutive Target Outcome Periods. A buffer ETF
will not participate in gains beyond the cap. In the event an investor purchases shares after the first day of a
Target Outcome Period and the ETF has risen in value to a level near the cap, there may be little or no ability
for that investor to experience an investment gain on their shares; however, the investor will remain vulnerable
to downside risk. A buffer ETF’s investment strategy is designed to deliver returns if shares are bought on the
first day and are held until the end of the Target Outcome Period subject to the cap. There can be no guarantee
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that a target outcome fund will be successful in its strategy to buffer against losses. A shareholder may lose their
entire investment. In the event an investor purchases shares after the first day of the target outcome period
defined in the fund's prospectus ("Target Outcome Period") or sells shares prior to the end of the Target
Outcome Period, the buffer that a fund seeks to provide may not be available.
• Fixed Income Investments: One of the most important risks associated with fixed income securities is interest
rate risk, the risk encountered in the relationship between bond prices and interest rates. The price of a bond will
change in the opposite direction of movements in prevailing interest rates. For example, as interest rates rise,
bond prices will generally fall. If an investor has to sell a bond prior to the maturity date, an increase in interest
rates could mean that the bondholder will experience a capital loss (i.e., selling the bond below its original
purchase price).
Reinvestment risk is the risk that the interest rate at which the interim cash flows can be reinvested will decline
and thus reinvestments will receive a lower interest rate. Reinvestment risk is greater for longer holding periods.
Default risk is commonly referred to as “credit risk” and is based on the probability that the issuer of the debt
obligation may default. Default risk is rated by quality ratings assigned by commercial rating companies.
Call risk is the risk related to call provisions on debt obligations. You should be aware of four risks associated
with call provisions.
1) The cash flow patterns of callable bonds are not known with certainty.
2) Since the issuer will typically exercise their right to call the bonds when interest rates have dropped,
you may be exposed to reinvestment risk. You would have to reinvest the proceeds after the bond is
called at relatively lower interest rates.
4)
3) The potential for capital appreciation of a callable bond is reduced relative to that of a non-callable
bond, because its price may not rise much above the price at which the issuer can call the issue.
If the issue is purchased at a premium, you may lose the difference between the purchase price and call
price.
Inflation risk arises because the value of the cash flows being received from a debt obligation may actually lose
purchasing power over the course of time due to the effects of inflation.
Liquidity risk depends on the ease with which an asset can be sold at or near its current value. The best indicator
to measure an issue’s liquidity is the size of the spread between the bid price and the ask price quoted by a
dealer. A wider spread on the asset indicates a greater liquidity risk. If you plan on holding a bond until its
maturity date, liquidity risk is less of a concern.
Finally, exchange rate risk, which is encountered in non-dollar denominated bonds or bonds whose payments
occur in a foreign currency, has unknown U.S. currency cash flows. The dollar cash flows are dependent on the
exchange rate at the time the payments are received. For example, consider a bond whose coupon payment is
paid out in Japanese yen. If the yen depreciates relative to the U.S. dollar, fewer net dollars will be received.
Conversely, if the yen should appreciate relative to the U.S. dollar, the investor will benefit by receiving more
net dollars.
Debt funds may include mortgage-backed securities and Treasury Inflation-Protected Securities (“TIPS”).
Mortgage-backed securities are subject to greater declines in value than traditional fixed income securities. This
is primarily due to decreased prepayments when interest rates fall, which could lengthen the average life of a
security. TIPS can provide a hedge against inflation, which helps preserve the purchasing power of the
investment. Because of this inflation adjustment feature, inflation protected bonds typically have lower yields
than conventional fixed rate bonds. These bonds will likely decline in price during periods of deflation, which
could result in losses.
A number of fund companies are offering Floating Rate funds, also called Bank Loan funds. The fund invests
mainly in floating rate loans (sometimes referred to as “adjustable rate loans”) typically issued to below
investment-grade companies. These loans may or may not hold a senior position in the capital structure of the
underlying U.S. and foreign corporations, partnerships or other business entities. Senior Loans may allow them
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to have priority of claim ahead of (or at least as high as) other obligations of a borrower in the event of
liquidation and may be collateralized or uncollateralized. They typically pay interest at rates that float above, or
are adjusted periodically based on, a benchmark that reflects current interest rates. These funds are designed for
investors seeking to participate in the market for Senior Loans, which may have higher risks than conventional
debt securities. Investors should be willing to assume the greater risks of short-term share price fluctuations and
the special credit risks that are typical for a fund that invests mainly in below investment-grade fixed income
securities. The fund is not designed for investors needing an assured level of current income. Lincoln
Investment’s use of these securities in its managed portfolios is only in well-diversified portfolios, to minimize
the risks to the portfolio yet allow for the potential participation in the higher yields associated with these higher
risk investments.
•
International Investing: Investing in the global market can assist with diversification of a portfolio but it is
important to consider some of the unique risks with such a strategy. Funds purchased for your account may
invest in international securities. Each country has unique rules and regulations covering corporations and their
stock markets which offer investors varying degrees of protection. There are special risks associated with
foreign investing, including currency fluctuations, economic instability and political developments. Fluctuations
in foreign currency-denominated securities may be magnified by changes in foreign exchange rates. These risks
may be magnified in emerging markets.
• Options: Certain options strategies are highly specialized contracts based on securities and entail greater than
ordinary investment risks.
For further information regarding the risks associated with Lincoln Investment’s Asset Management Program Model
Portfolios and the best suited investment strategies for your account(s), please review the risk level of the Asset
Management Program Model Portfolio and your fund prospectus(es) or consult with your Advisor. Lincoln
Investment also provides information regarding its Asset Management Program strategists on its website at
www.lincolninvestment.com.
Advisors may offer comprehensive or limited financial planning services for a fee. Financial planning services may
include, but are not limited to, retirement, college, tax, business succession planning or insurance needs analysis,
and assistance with estate distribution matters. Should the client choose to implement the recommendations
contained in the client’s plan, the implementation of those recommended strategies is entirely at the client’s
discretion. All other fee-based services, such as asset-based investment advice or asset management services through
Lincoln Investment as described above, would require that you enter into a separate written investment advisory
agreement. The investment strategies of Lincoln Investment and associated risks are described above.
Item 9: Disciplinary Information
Provided below is a summary of legal or disciplinary events within the past ten years that may be material to your
evaluation of Lincoln Investment’s advisory business.
January 27, 2016: Lincoln Investment signed a Letter of Acceptance, Waiver and Consent (“AWC”) with FINRA.
Without admitting or denying the findings, Lincoln Investment accepted a censure and $75,000 fine relating to the
supervisory review of consolidated reports produced by Lincoln Investment’s representatives and provided to
clients. Lincoln Investment further agreed to adopt and implement procedures reasonably designed to enhance the
enforcement of our supervisory systems and procedures to ensure effective review of consolidated reports produced
by representatives and provided to clients.
September 25, 2018: Lincoln Investment signed a Letter of Acceptance, Waiver and Consent (“AWC”) with
FINRA. Without admitting or denying the findings, Lincoln Investment, relating to its broker-dealer, accepted a
censure and $35,000 fine relating to Lincoln Investment’s failure to implement reasonably designed surveillance
procedures to monitor its registered representatives’ rates of effecting variable annuity exchanges where the firm
was not the broker of record for the variable annuity that was being exchanged. After FINRA raised this issue,
Lincoln Investment corrected its surveillance report to include all variable annuity exchanges.
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December 10, 2020: Lincoln Investment signed a Letter of Acceptance, Waiver and Consent (“AWC”) with
FINRA. Without admitting or denying the findings, Lincoln Investment, relating to its broker-dealer, accepted a
censure and $35,000 fine relating to Lincoln Investment’s failure to implement reasonably designed supervisory
procedures or written supervisory procedures to monitor withdrawals or transmittal of funds from customer
accounts, and as a result, in the fall of 2017, impostors stole or attempted to steal customer funds by requesting
transfers from the accounts of two Lincoln Investment customers. Following its discovery of these events, Lincoln
Investment took remedial measures to address the deficiencies in its supervisory system.
Your Advisor should provide along with this brochure a Form ADV 2B Brochure Supplement (“Form ADV 2B
Brochure Supplement” or “Financial Professional BIO Brochure”) that describes your Advisor’s education, business
experience, professional designations and material legal or disciplinary history, if any. For further information
regarding Lincoln Investment's disciplinary events you may go to www.adviserinfo.sec.gov or
https://brokercheck.finra.org and search for Lincoln Investment Planning, LLC.
Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer and Insurance Agency
In addition to being a registered investment adviser, Lincoln Investment is also a registered broker-dealer and an
insurance agency. This presents a conflict of interest. Please refer to the "Other Compensation to Lincoln Investment
and Our Conflicts of Interest" section under Item 5 of this brochure for information regarding Lincoln Investment's
conflicts of interests as a broker-dealer and insurance agency and how we address these conflicts.
Advisors’ Other Business Activities and Affiliations
Lincoln Investment's Advisors are primarily independent contractors, many of whom hold themselves out to the
public under a name other than Lincoln Investment and offer other financial services independent of Lincoln
Investment, such as life, health, disability, long term care and fixed annuity insurance products, real estate, and
business planning services. A few of our Advisors may also be qualified lawyers and accountants or hold certain
professional designations not required by us to conduct business through Lincoln Investment. These services are
offered independent of Lincoln Investment as outside business activities and Lincoln Investment assumes no
responsibility or supervision over these activities. Please refer to the "Other Compensation to Lincoln Investment
and Our Conflicts of Interest" section under Item 5 of this brochure, or refer to your Advisor’s Form ADV 2B
Brochure Supplement, for more information regarding outside business activities and how we address these
conflicts. You may go to www.adviserinfo.sec.gov or https://brokercheck.finra.org for further information regarding
your Advisor’s other business activities or affiliations.
Independent Registered Investment Advisers
Lincoln Investment permits certain Advisors to maintain or affiliate with an independent registered investment
advisory firm which may offer advisory services similar to Lincoln Investment or its affiliate, Capital Analysts.
Such independent registered investment advisory firms are unaffiliated with Lincoln Investment and Capital
Analysts. These services are offered independent of Lincoln Investment and Capital Analysts as private securities
transactions. Your Advisor can be associated with Lincoln Investment, Capital Analysts, or an unaffiliated registered
investment adviser as an investment adviser representative, and/or associated with Lincoln Investment as a
registered representative of Lincoln Investment’s broker-dealer. As such, your Advisor can be in a position to offer
you advisory services under Lincoln Investment, Capital Analysts, the unaffiliated independent registered
investment advisory firm, and brokerage services under Lincoln Investment’s broker-dealer, or all of the above.
Advisors affiliated with other registered investment advisory firms must provide to their clients that firm’s Form
ADV Part 2A, applicable supplements, advisory agreements and disclosures if you are opening an account with such
other investment advisory firm. To inquire as to whether your Advisor is affiliated with a separate registered
investment advisory firm, it will be listed on their Financial Professional BIO Brochure (Form ADV Part 2B), a
copy of which they are required to provide to you, or you may go to www.adviserinfo.sec.gov or
https://brokercheck.finra.org.
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Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics
As an investment adviser, Lincoln Investment has established a Code of Ethics under which all Lincoln Investment
supervised employees and Advisors must comply. In our capacity as an investment adviser, Lincoln Investment
owes a fiduciary duty to our investment advisory clients and is held to legal standards under applicable federal and
state securities laws. Lincoln Investment has a fiduciary responsibility to (1) provide investment advice that the
Advisor believes is in the best interest of the client; (2) place clients interest above the interests of Lincoln
Investment and your Advisor by providing full and fair disclosure of all material facts and conflicts of interest to
clients, and (3) conduct all personal securities transactions consistent with Lincoln Investment's Code of Ethics.
Lincoln Investment's Advisors are held to a professional standard that requires them to avoid any abuse of their
position of trust and responsibility, not take inappropriate advantage of their positions, comply with applicable
securities laws and regulations, and maintain confidentiality of client's financial circumstances.
You may request a full copy of Lincoln Investment's Code of Ethics from your Advisor or Lincoln Investment's
Compliance Department at (800) 242-1421, ext. 4300.
Participation or Interest in Client Transactions and Personal Trading
Lincoln Investment, its Advisors, members of the IM&R Team, and employees may buy or sell for themselves
securities that are also recommended to clients. This presents a conflict of interest because trading by an Advisor or
employee, including members of the IM&R Team, in a personal securities account in the same security prior to
placing client trades can disadvantage the client. Lincoln Investment addresses this conflict of interest by requiring
in its Code of Ethics that Lincoln Investment Advisors and employees, including the IM&R Team, must report
certain personal securities transactions and holdings to Lincoln Investment.
In addition, Lincoln Investment’s Code of Ethics requires that the Advisor and his or her employees must give first
priority to client securities purchases and sales over their own personal transactions in the same security. This means
that any transaction by the Advisor or his/her employee must be placed either simultaneously with your transaction
in the same security (i.e., aggregating the orders and sharing in the same price and execution costs) or after all client
trades for that security are placed on the same trading day. While the latter will not guarantee that you will receive
the best price, it does establish that the client trades will occur at the same time as or before that of the Advisor or
his/her employees. At no time may an Advisor participate in the profits or losses of an investor's account. Personal
trading accounts of Advisors are monitored by Lincoln Investment to ensure compliance.
Other than as described in its Code of Ethics and Insider Trading policies and procedures, Lincoln Investment does
not impose on itself or any person associated with it any restrictions in connection with the purchase or sale, directly
or indirectly, of investments for his or her own account.
Item 12: Brokerage Practices
Your advisor will recommend a platform based on the type of account you wish to open (brokerage or advisory), the
type of securities you wish to invest in (mutual funds only or exchange traded securities), and the advisory programs
that are available on that platform through Lincoln Investment.
Some advisory services offered by Lincoln Investment specify one or more custodians or clearing firms, including
Pershing, where the assets must reside in order for the advisory services to be engaged. For many of these services,
this allows Lincoln Investment the capability to have ongoing access to the assets for trading and viewing purposes.
Lincoln Investment acts as introducing broker-dealer for advisory accounts held at Pershing, with whom Lincoln
Investment maintains its primary clearing arrangement. When Lincoln Investment is recommending that your
account and your transactions be placed with us as introducing broker-dealer for accounts held at Pershing or
another broker-dealer, we cannot guarantee that Pershing will be the lowest cost platform for you, or that you will
receive the most favorable execution on your transactions, which can cost you more money. Not all investment
advisers require the use of a specific broker-dealer/custodian.
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In its sole discretion, Lincoln Investment can approve the use of account custodians other than Pershing. Third-party
custodians have their own platform, administrative and trading costs to which you will be subject. If a client should
request, and Lincoln Investment approve, the use of a broker-dealer/custodian other than Pershing for securities
transaction execution, the client should be aware that Lincoln Investment will generally be unable to negotiate
commissions or other fees and charges for the client’s account. Therefore, we cannot guarantee that the platform
recommended to you will be the lowest cost platform for you.
Please consult with your Advisor regarding which broker-dealer/custodians may be required for the advisory
service(s) you wish to select or invest. When selecting a custodian, Lincoln Investment can consider certain factors,
such as reasonableness of applicable fees, products and services offered, and other qualitative factors such as the
broker-dealer’s execution capability, financial responsibility, and responsiveness.
Brokerage or custodial account fees and/or transaction charges, if any, are disclosed to you at the time your account
is established for accounts held at Pershing. Pershing has its own platform, administrative and transaction-related
fees. For platforms other than Pershing, you should review the applicable platform application, applicable fund
prospectus and/or any additional disclosure documents and agreements which outline the costs specific to the
platform. Brokerage or custodial account fees and/or transaction charges can change over time. You should review
the specific platform disclosure documents. Lincoln Investment shares in fees from certain clearing firms, such as
Pershing. Please refer to the "Other Compensation to Lincoln Investment and Our Conflicts of Interest" section
under Item 5 of this brochure for information regarding Lincoln Investment's conflicts of interests with regard to
different platforms, including Pershing. For a description of trading and administrative fees associated with where
your account will be held, view the specific platform disclosure document for your account found at
www.lincolninvestment.com/Disclosures.
Trade Aggregation Policy
Offering advisory services to clients includes an obligation on the part of Lincoln Investment and its Advisors to
ensure that the allocation of investment opportunities or trades among its various client accounts, as well as accounts
in which it (or its affiliates) has a proprietary interest, is performed in a manner that is fair and equitable in its
treatment of all clients and, wherever possible, avoids conflicts of interest.
Therefore, Lincoln Investment has adopted an Aggregated Trade Allocation Policy to be used by Lincoln
Investment and Advisors who have been granted discretionary authority by clients when placing orders in the same
security on the same day for one or more clients or accounts. By aggregating orders, Advisors ensure that all clients
receive that same price for the security on the same day. This policy is intended to prevent favoritism of one client
over another and establish a rational and predictable fashion for the allocation of trade pricing on a given day for a
given security.
Trades in the following situations will typically be aggregated:
• Lincoln Investment or the Advisor recognizes ahead of time that he/she will be buying or selling the same
security in more than one client account on the same day;
• Lincoln Investment or the Advisor reasonably believes that aggregating may facilitate a better execution
price for all clients; and
• The securities involved are exchange-traded rather than open-ended funds or annuity sub- accounts.
Trades in the following situations will not typically be aggregated:
• Where prohibited by or inconsistent with the client’s investment management agreement;
• The trade is a result of the implementation of a change of investment strategy for a specific client;
• The trade is part of a new client’s account allocation;
• The trade is a result of rebalancing to an asset allocation policy or pursuant to an account review with the
client; and/or
• Lincoln Investment or the Advisor reasonably believes that aggregating orders would adversely impact
price and/or best execution for the client.
If the security to be purchased in aggregate cannot be obtained in the total quantity required, the allocation of that
security will be made on a pro rata basis determined by the ratio of the quantity obtained to the share quantity
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required to implement the investment strategy. Each client would participate in the order at the average price for all
of the transactions on a given day.
If implementing the trade requires transactions over several days, each day’s execution shares and average price on
all executions for that day shall be allocated by the end of each trading day or no later than the next trading day. In
the course of executing an aggregated trade, a list of clients’ accounts and shares to be bought or sold is to be
prepared. This is to be used in allocating the trade and the list is to be kept as a record with the original aggregated
trade order. Allocation of shares, prices, and costs shall be done on a timely basis, in no event to exceed two (2)
trading days following execution. Lincoln Investment and your Advisor shall not receive any additional
compensation for aggregating trades.
The overlay manager can choose to implement trades in accordance with their own trade aggregation/rotation policy
that differs from the policy outlined herein. If applicable, please see your overlay manager’s Form ADV 2A and/or
Appendix I for additional details.
Lincoln Investment’s advisory assets held at Pershing comprise the majority of the firm’s managed assets. In order
to minimize financial impact to the majority of clients, the trade allocation policy will not apply in the event of
significant market volatility and Lincoln Investment will give priority to advisory assets held at Pershing over other
custodians.
Discretionary model portfolios managed by Lincoln Investment are generally traded in concert as described above;
however, there are certain portfolios that are managed by Lincoln Investment on a custom basis which trade
separately from the models.
Item 13: Review of Accounts
Account Review Policies and Procedures
Your Advisor is responsible to ensure that the recommended advisory service is in your best interest. Many of our
programs are managed to defined levels of risk, so choosing the appropriate risk level or tolerance for market
fluctuation and potential loss of investment is an important part of your decision. Furthermore, the Financial Advisor
Fee portion of your fees compensates your Advisor for his or her services. If Lincoln Investment or your Advisor
has been granted full discretionary trading authority over your advisory account, Lincoln Investment or your
Advisor will provide ongoing monitoring and will make changes in your account as deemed necessary. For all other
advisory accounts, you and your Advisor will review your advisory account’s objectives, investments and
performance relative to your objectives and financial situation at least annually to allow your Advisor the
opportunity to recommend changing or maintaining the objectives or investments in your account. It is important
therefore that you take the time to speak with your Advisor regarding your financial objectives and needs and
particularly when there is a material life event that could affect or change your investment objectives or financial
needs.
See your investment advisory agreement for the level of discretion and monitoring granted to Lincoln Investment or
your Advisor, which can vary based on the advisory program you select.
Lincoln Investment has procedures in place to supervise the investment advisory activities of its Advisors. If you
have any questions about the trading or recommendations in your account, please call your Advisor's Designated
Supervisor.
Should you engage your Advisor for planning services, including financial planning, your Advisor is responsible to
ensure that the planning services are delivered to you on a timely basis. However, the timing of most deliverables
will be dependent on you to provide your Advisor with all relevant data and other information to enable your
Advisor to perform the engaged services.
Planning Services should be completed within six (6) months of the engagement (signing of the Planning
Service Agreement). In all cases, the Planning Services Agreement terminates upon delivery or
completion of services or after one (1) year from engagement, whichever occurs first, unless exceptions
have been granted by Lincoln Investment’s Supervision Department. Failure to deliver a plan within the
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prescribed timeframe may result in a full refund of any pre-paid fees to you. Monitoring or updating of
recommended plan will only occur if client implements plan recommendations through Advisor under a
separate advisory agreement.
A Supervising Principal will review the Planning Services Agreement prepared by your Advisor to ensure the
recommendations are appropriate and services are complete. If you have any questions about the
recommendations, please call your Advisor's Designated Supervisor.
Lincoln Investment’s IM&R Team routinely reviews the advisory services managed, sponsored, and/or offered by
Lincoln Investment’s Sub-Advisers. A description of the IM&R Team is provided in the supplement at the end of
this brochure. The IM&R Team performs the following roles on Lincoln Investment’s behalf:
• The management of all Lincoln Investment managed model portfolios
• The selection of advisory services offered by Lincoln Investment
• The monitoring of Sub-Advisers and third-party money managers offered by Lincoln Investment
• The removal of Sub-Advisers and third-party money managers offered by Lincoln Investment
Written Reports
At minimum, you will receive a quarterly account statement from the custodian who carries your account. This
statement will reflect all transactions that have occurred in your account as well as identify fees, including the
advisory fee, deducted from your account. This is the most important statement you will receive and should be
reviewed immediately upon receipt to ensure accuracy in your holdings and transactions.
Some Advisors and advisory services may also provide you supplemental advisory reports which may include
performance reports, aggregated account reviews, or a portfolio snapshot. These supplemental reports, typically
generated on a quarterly, semiannual or annual basis, are made available to you either electronically or will be
delivered to you. These supplemental reports are provided as a service to you and should not replace your custodial
statement(s). We urge you to compare these supplemental reports to the custodial account statements you receive. If
you find any discrepancies, please contact your Advisor or Lincoln Investment.
Item 14: Client Referrals and Other Compensation
Advisors and Lincoln Investment may act as a promoter and introduce you to a third-party money manager. In
Promoter relationships, we do not act as a Co-Adviser. For this introduction, the third-party money manager will pay
Lincoln Investment a Promoter/Referral Fee, which we will share with your Advisor. This fee, which is typically an
ongoing portion of the fee collected from you by the manager, must be disclosed to you at the time of the
introduction. Please refer to the disclosure provided to you at the time of the referral to determine the fee paid to
Lincoln Investment and your Advisor. Please review the third-party money manager’s ADV Part 2A for more
information about their advisory fees. On occasion, Lincoln Investment compensates or permits an Advisor to
compensate an outside party (for example, an attorney, accountant, bank or credit union) for client referrals to one of
our advisory services. Other than banks and credit unions, no new relationships in which Lincoln Investment
compensates or permits an Advisor to compensate an outside party for client referrals are permitted.
For details regarding other compensation received by Lincoln Investment and your Advisor and associated conflicts
of interest, see Item 5: Fees and Compensation in the section titled "Other Compensation to Lincoln Investment and
Our Conflicts of Interest."
Item 15: Custody
Advisers Act Rule 206(4)-2 (the “Custody Rule”) sets forth extensive requirements regarding possession or custody
of client funds or securities. The Custody Rule is designed to ensure that registered investment advisers with access
to client assets (securities or cash) establish procedures to protect the assets from misappropriation, conversion,
insolvency of the adviser or unauthorized reallocation of securities among clients. Lincoln Investment’s advisory
account assets are held with unaffiliated third-party custodians who serve as qualified custodians and provide clients
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with, at minimum, quarterly account statements. Pershing acts as the custodian for the majority of Lincoln
Investment’s advisory programs. For some advisory assets, the firm is deemed to have custody and is therefore
required to undergo an annual surprise exam.
If you have advisory assets held at Pershing or another qualified custodian, you will receive, at minimum, a
quarterly statement from the qualified custodian(s) of your advisory assets. We urge you to carefully review these
statements and compare them to any reports provided to you by Lincoln Investment or your Advisor. The
information in these reports may vary from your custodial statements based on accounting procedures and reporting
dates. Please contact your Advisor or Lincoln Investment regarding any statement discrepancies.
Item 16: Investment Discretion
Depending on the advisory service chosen, Lincoln Investment, its Advisors, a third-party manager or an overlay
manager may have discretionary authority to determine which securities shall be bought and sold, and the total
amount to be bought or sold in your advisory account(s). This authorization does not grant Lincoln Investment, its
Advisors, or, if applicable, any third-party manager or overlay manager, the right to withdraw any funds or securities
from your advisory account(s), except as specifically authorized in your advisory agreement for the deduction of
advisory fees. Your advisory agreement or account application will identify whether and to what extent you are
giving discretionary trading authority for your advisory account(s) to Lincoln Investment, your Advisor, a third-
party money manager or overlay manager.
At no time during the engagement of Planning Services may an Advisor be assigned discretionary authority over any
of your accounts and neither should you provide your Advisor with any of your personal passwords or other access
codes to any online accounts. Working with you on Planning Services does not grant Lincoln Investment or its
Advisors the right to withdraw any funds or securities from your account(s), except as specifically authorized by you
to pay the Planning Service Fees.
Item 17: Voting Client Securities
Lincoln Investment and its Advisors may not, and do not, accept authority to vote clients’ proxies for any securities
in an advisory or non-advisory service. You will receive proxies and solicitations for voting client securities directly
from your custodian, transfer agent or us, or a designee thereof.
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Form ADV Part 2B Brochure Supplement
Lincoln Investment Planning, LLC
Form ADV Part 2B Brochure Supplement
As of March 31, 2026
Principal Office:
601 Office Center Drive
Fort Washington, PA 19034
Investment Management & Research
Shashi Mehrotra, CFA®
Christopher J. Surrichio, CFA®
Gerald E. Burhop, CFA®, CIPM®
Brian Moran
Steven E. Mueller, CFA®
This brochure supplement provides you with information about the five (5) members of the Investment Management
& Research Team (“IM&R Team”) of Lincoln Investment Planning, LLC (“Lincoln Investment”) who have the
most significant day-to-day management responsibilities for the Lincoln Investment managed portfolios. This
information supplements the information contained in the Lincoln Investment Form ADV 2A and/or Wrap Fee
Program brochure, which you should have received.
If you have any questions about the contents of this brochure supplement, please contact us at (800) 242-1421.
Additional information about each of the members of the IM&R Team is available through the U.S. Securities and
Exchange Commission at www.adviserinfo.sec.gov.
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March 2026
Shashi Mehrotra, CFA®
EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE
Year of Birth: 1966
Education
Master of Business Administration, Florida Atlantic University, 1994
Bachelor of Engineering, Osmania University, 1989
Business Experience
Lincoln Investment Planning, LLC, July 2025 – Present, Senior Vice President and Chief Investment Officer
Lincoln Investment Planning, LLC, May 2019 – July 2025, Senior Vice President and Chief Investment Strategist
Capital Analysts, LLC, July 2025 – Present, Senior Vice President and Chief Investment Officer
Capital Analysts, LLC, September 2019 – Present, Investment Adviser Representative
Lincoln Investment Planning, LLC, June 2019 – Present, Investment Adviser Representative
Lincoln Investment Planning, LLC, January 2017 – Present, Registered Representative
Legend Advisory, LLC, April 2011 – September 2019, Investment Adviser Representative
Legend Equities Corporation, January 1996 – January 2017, Registered Representative
Legend Advisory, LLC, July 1995 – September 2019, Chief Investment Officer/Chief Operating Officer
Professional Licenses/Designations
Mr. Mehrotra holds general securities principal and general securities representative licenses with Lincoln
Investment.
In addition, Mr. Mehrotra maintains the following professional designation:
Chartered Financial Analyst® (CFA®)
Designation Status: Currently offered and recognized by the issuing organization
Issuing Organization: CFA Institute
Prerequisites/Experience Required: Candidate must meet one of the following requirements: Undergraduate
degree and four years of professional experience involving investment decision-making, or four years
qualified work experience (full time, but not necessarily investment related)
Education Requirements: Self-study program (250 hours of study for each of the three levels)
Exam Type: Three course exams
Continuing Education Requirements: None
DISCIPLINARY INFORMATION
Mr. Mehrotra has no material legal or disciplinary events to report.
OTHER BUSINESS ACTIVITIES
Mr. Mehrotra sits on the Board of Directors of Aqua Pulsar, a water-engineering company, where he assists with
strategic financial and investment decisions. You are under no obligation as an investment advisory client to
purchase any outside products or services that Mr. Mehrotra may offer.
ADDITIONAL COMPENSATION
Generally, members of the IM&R Team IM&R Team are compensated through salaries and bonuses. They may be
compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan.
Salaries are fixed annually and are driven by the marketplace. Compensation is not affected by an increase in
advised assets.
Please see the Services, Fees and Compensation section of the accompanying Form ADV 2A and/or Wrap Program
brochure. This section describes in detail other potential forms of compensation in addition to the advisory fee paid
to Lincoln Investment.
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March 2026
SUPERVISION
The individual responsible for monitoring the advisory activities of Mr. Mehrotra is Ed Forst, Chief Executive
Officer of Lincoln Investment Planning, LLC and Capital Analysts, LLC. Mr. Forst or his designee is responsible to
review the duties, responsibilities and trading assigned to Mr. Mehrotra. If you have any questions about the trading
in your account, please call Mr. Forst at (800) 242-1421.
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March 2026
Christopher J. Surrichio, CFA®
EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE
Year of Birth: 1970
Education
Bachelor of Arts, Economics, Boston College, 1992
Business Experience
Lincoln Investment Planning, LLC, July 2025 – Present, Deputy Chief Investment Officer
Capital Analysts, LLC, July 2025 – Present, Deputy Chief Investment Officer
Capital Analysts, LLC, June 2012 – July 2025, Vice President and Portfolio Manager
Capital Analysts, LLC, June 2012 – Present, Investment Adviser Representative
Lincoln Investment Planning, LLC, June 2012 – Present, Investment Adviser Representative and Registered
Representative
Capital Analysts, Incorporated, 2002 – June 2012, Vice President
Professional Licenses/Designations
Mr. Surrichio holds general securities principal, general securities representative and research analyst licenses with
Lincoln Investment, as well as through its affiliated RIA, Capital Analysts, LLC.
In addition, Mr. Surrichio maintains the following professional designations:
Chartered Financial Analyst® (CFA®)
Designation Status: Currently offered and recognized by the issuing organization
Issuing Organization: CFA Institute
Prerequisites/Experience Required: Candidate must meet one of the following requirements:
Undergraduate degree and four years of professional experience involving investment decision-making, or
four years qualified work experience (full time, but not necessarily investment related)
Educational Requirements: Self-study program (250 hours of study for each of the three levels)
Examination Type: Three course exams
Continuing Education/Experience Requirements: None
DISCIPLINARY INFORMATION
Mr. Surrichio has no material legal or disciplinary events to report.
OTHER BUSINESS ACTIVITIES
The IM&R Team is responsible for the asset management programs managed by Lincoln Investment and Capital
Analysts, LLC, an affiliated investment adviser. The management of portfolios for both investment advisers may
create a conflict.
Mr. Surrichio has no other business activities to report.
ADDITIONAL COMPENSATION
Generally, members of the IM&R Team IM&R Team are compensated through salaries and bonuses. They may be
compensated with profit sharing contributions and, in some cases, participation in a long-term incentive plan.
Salaries are fixed annually and are driven by the marketplace. Compensation is not affected by an increase in
advised assets.
Please see the Services, Fees and Compensation section of the accompanying Form ADV 2A and/or Wrap Program
brochure. This section describes in detail other potential forms of compensation in addition to the advisory fee paid
to Lincoln Investment or Capital Analysts.
SUPERVISION
The individual responsible for monitoring the advisory activities of Mr. Surrichio is Shashi Mehrotra, Senior Vice
President and Chief Investment Officer. Mr. Mehrotra or his designee is responsible to review the duties,
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responsibilities and trading assigned to Mr. Surrichio. If you have any questions about the trading in your account,
please call Mr. Mehrotra at (561) 307-0906.
5
March 2026
Gerald E. Burhop, CFA®, CIPM®
EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE
Year of Birth: 1964
Education
Master of Business Administration, Finance, Temple University, 1998
Bachelor of Science, Agricultural Journalism/Advertising, University of Wisconsin-Madison, 1988
Business Experience
Lincoln Investment Planning, LLC, 2002 – Present, Vice President and Portfolio Manager
Lincoln Investment Planning, LLC, October 1999 – Present, Registered Representative
Lincoln Investment Planning, LLC, April 2011 – Present, Investment Adviser Representative
Lincoln Investment Planning, LLC, March 1999 – 2002, Mutual Fund Financial Analyst
Capital Analysts, LLC, March 2014 – Present, Investment Adviser Representative
Professional Licenses/Designations
Mr. Burhop holds general securities principal and general securities representative licenses with Lincoln Investment,
as well as through its affiliated RIA, Capital Analysts, LLC.
In addition, Mr. Burhop maintains the following professional designations:
Chartered Financial Analyst® (CFA®)
Designation Status: Currently offered and recognized by the issuing organization
Issuing Organization: CFA Institute
Prerequisites/Experience Required: Candidate must meet one of the following requirements:
Undergraduate degree and four years of professional experience involving investment decision-making, or
four years qualified work experience (full time, but not necessarily investment related)
Educational Requirements: Self-study program (250 hours of study for each of the three levels)
Examination Type: Three course exams
Continuing Education/Experience Requirements: None
Certificate in Investment Performance Measurement™ (CIPM®)
Designation Status: Currently offered and recognized by the issuing organization
Issuing Organization: CFA Institute
Prerequisites/Experience Required: Candidate must meet one of the following requirements: Two years of
professional experience “substantially entailing performance-related activities,” or four years of investment
industry work experience
Educational Requirements: Self-study program (100 or more hours of study for each of the two levels)
Examination Type: Two level exams (Principles and Expert)
Continuing Education/Experience Requirements: Complete and record 15 hours of qualifying activities
annually
DISCIPLINARY INFORMATION
Mr. Burhop has no material legal or disciplinary events to report.
OTHER BUSINESS ACTIVITIES
The IM&R Team is responsible for the asset management programs managed by Lincoln Investment and Capital
Analysts, LLC, an affiliated investment adviser. The management of portfolios for both investment advisers may
create a conflict.
Mr. Burhop has no other business activities to report.
ADDITIONAL COMPENSATION
Generally, members of the IM&R Team are compensated through salaries and bonuses. They may be compensated
with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed
annually and are driven by the marketplace. Compensation is not affected by an increase in advised assets.
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March 2026
Please see the Services, Fees and Compensation section of the accompanying Form ADV 2A and/or Wrap Program
brochure. This section describes in detail other potential forms of compensation in addition to the advisory fee paid
to Lincoln Investment or Capital Analysts.
SUPERVISION
The individual responsible for monitoring the advisory activities of Mr. Burhop is Shashi Mehrotra, Senior Vice
President and Chief Investment Officer. Mr. Mehrotra or his designee is responsible to review the duties,
responsibilities and trading assigned to Mr. Burhop. If you have any questions about the trading in your account,
please call Mr. Mehrotra at (561) 307-0906.
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March 2026
Brian Moran
EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE
Year of Birth: 1967
Education
Master of Business Administration, Drexel University, 2012
Bachelor of Science, Economics, University of Pennsylvania, 1990
Business Experience
Capital Analysts, LLC, May 2015 – Present, Vice President of Trading and Portfolio Manager
Capital Analysts, LLC, June 2012 – May 2015, Institutional Trading Manager
Capital Analysts, LLC, June 2012 – Present, Investment Adviser Representative
Lincoln Investment Planning, LLC, June 2012 – Present, Registered Representative
Lincoln Investment Planning, LLC, August 2012 – Present, Investment Adviser Representative
Capital Analysts, Incorporated, 2001 – June 2012, Institutional Trading Manager
Professional Licenses/Designations
Mr. Moran holds general securities principal, general securities representative, municipal securities principal, and
options principal licenses with Lincoln Investment, as well as through its affiliated RIA, Capital Analysts, LLC.
DISCIPLINARY INFORMATION
Mr. Moran has no material legal or disciplinary events to report.
OTHER BUSINESS ACTIVITIES
The IM&R Team is responsible for the asset management programs managed by Lincoln Investment and Capital
Analysts, LLC, an affiliated investment adviser. The management of portfolios for both investment advisers may
create a conflict.
Mr. Moran has no other business activities to report.
ADDITIONAL COMPENSATION
Generally, members of the IM&R Team are compensated through salaries and bonuses. They may be compensated
with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed
annually and are driven by the marketplace. Compensation is not affected by an increase in advised assets.
Please see the Services, Fees and Compensation section of the accompanying Form ADV 2A and/or Wrap Program
brochure. This section describes in detail other potential forms of compensation in addition to the advisory fee paid
to Lincoln Investment or Capital Analysts.
SUPERVISION
The individual responsible for monitoring the advisory activities of Mr. Moran is Shashi Mehrotra, Senior Vice
President and Chief Investment Officer. Mr. Mehrotra or his designee is responsible to review the duties,
responsibilities and trading assigned to Mr. Moran. If you have any questions about the trading in your account,
please call Mr. Mehrotra at (561) 307-0906.
8
March 2026
Steven E. Mueller, CFA®
EDUCATIONAL BACKGROUND & BUSINESS EXPERIENCE
Year of Birth: 1982
Education
Bachelor of Science, Finance, Temple University, 2012
Business Experience
Lincoln Investment Planning, LLC, September 2025 – Present, Assistant Portfolio Manager
Lincoln Investment Planning, LLC, August 2017 – September 2025, Senior Research Analyst
Lincoln Investment Planning, LLC, August 2014 – August 2017, Research Analyst
Lincoln Investment Planning, LLC, September 2013 – August 2014, Internal Wholesaler, Asset Management
Lincoln Investment Planning, LLC, September 2013 – Present, Investment Adviser Representative
Lincoln Investment Planning, LLC, March 2013 – Present, Registered Representative
Professional Licenses/Designations
Mr. Mueller holds general securities principal, general securities representative, and uniform combined state law
examinations with Lincoln Investment.
Chartered Financial Analyst® (CFA®)
Designation Status: Currently offered and recognized by the issuing organization
Issuing Organization: CFA Institute
Prerequisites/Experience Required: Candidate must meet one of the following requirements: Undergraduate
degree and four years of professional experience involving investment decision-making, or four years
qualified work experience (full time, but not necessarily investment related)
Education Requirements: Self-study program (250 hours of study for each of the three levels)
Examination Type: Three course exams
Continuing Education/Experience Requirements: None
DISCIPLINARY INFORMATION
Mr. Mueller has no material legal or disciplinary events to report.
OTHER BUSINESS ACTIVITIES
The IM&R Team is responsible for the asset management programs managed by Lincoln Investment and Capital
Analysts, LLC, an affiliated investment adviser. The management of portfolios for both investment advisers may
create a conflict.
Mr. Mueller has no other business activities to report.
ADDITIONAL COMPENSATION
Generally, members of the IM&R Team are compensated through salaries and bonuses. They may be compensated
with profit sharing contributions and, in some cases, participation in a long-term incentive plan. Salaries are fixed
annually and are driven by the marketplace. Compensation is not affected by an increase in advised assets.
Please see the Services, Fees and Compensation section of the accompanying Form ADV 2A and/or Wrap Program
brochure. This section describes in detail other potential forms of compensation in addition to the advisory fee paid
to Lincoln Investment or Capital Analysts.
SUPERVISION
The individual responsible for monitoring the advisory activities of Mr. Mueller is Christopher J. Surrichio, Deputy
Chief Investment Officer. Mr. Surrichio or his designee is responsible to review the duties, responsibilities and
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March 2026
trading assigned to Mr. Mueller. If you have any questions about the trading in your account, please call Mr.
Surrichio at (215) 881-7733.
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March 2026