LPL FINANCIAL LLC

OPTIMUM MARKET PORTFOLIOS (OMP) PROGRAM BROCHURE LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 October 22, 2025 This program brochure provides information about the qualifications and business practices of LPL Financial (“LPL”). If you have any questions about the contents of this brochure, please contact LPL at lplfinancial.adv@lplfinancial.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about LPL also is available on the SEC’s website at https://adviserinfo.sec.gov. ITEM 1 COVER PAGE ITEM 2 MATERIAL CHANGES The following is a summary of certain changes made to this Brochure from the time of the most recent annual update dated March 28, 2024. Item 6 was updated to provide that effective November 24, 2025, LPL will be responsible for voting proxies solicited by, or with respect to, the issuers of any securities held in the account, except to the extent otherwise prohibited by law and unless clients opt to retain voting responsibility. Additional risk disclosures were added in Item 6 related to third-party service providers’ or any counterparties’ potential use of artificial intelligence and machine learning. Item 9 was updated to provide information regarding disciplinary events involving (i) a settlement with the SEC that included a $50 million fine for failing to maintain required records of certain business-related communications; and (ii) a settlement with the SEC that included an $18 million fine for LPL not following its anti-money laundering policies for its customer identification program and ongoing customer due diligence obligations. Item 9 was also updated to reflect the following setup fee charges payable to LPL by model managers or product sponsors, if applicable to the program: (i) a yearly $5,000 per strategy fee for annual due diligence reviews and maintenance; (ii) the one-time sponsor-level mutual fund setup fee was reduced from $40,000 to $15,000, with the per-fund setup fee increasing from $5,000 to $7,500; (iii) up to $15,000 as a sponsor level due diligence fee for exchange traded products; and (iv) a $5,000 per- trust fee for each unit investment trust. In addition, Item 9 was updated to disclose conflicts related to LPL’s decision to make certain product sponsors available on the applicable platforms when certain sponsors reimburse LPL for technology development related costs associated with the launch or maintenance of a platform, tool, or service. Item 9 was also updated to disclose risks related to LPL’s ability to block or review client orders before they are directed to an exchange or market maker for execution. This may result in a delay in execution, which could cause (i) a difference between execution price and the displayed quote at the time the order was entered; and (ii) a limit order becoming ineligible for execution. Item 9 was also updated to include additional information about LPL’s Dividend Reinvestment Program (DRP). ITEM 3 TABLE OF CONTENTS ITEM 1 COVER PAGE ................................................................................................................................................ 1 ITEM 2 MATERIAL CHANGES ................................................................................................................................... 1 ITEM 3 TABLE OF CONTENTS ................................................................................................................................. 1 ITEM 4 SERVICES, FEES AND COMPENSATION ..................................................................................................... 2 ITEM 5 ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS .............................................................................. 5 ITEM 6 PORTFOLIO MANAGER SELECTION AND EVALUATION .......................................................................... 5 ITEM 7 CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ............................................................ 8 ITEM 8 CLIENT CONTACT WITH PORTFOLIO MANAGERS ................................................................................... 8 ITEM 9 ADDITIONAL INFORMATION ...................................................................................................................... 8 A 1 2 – E Q H – 1 0 2 5 P a g e 1 L P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS - PROGRAM BROCHURE ITEM 4 SERVICES, FEES AND COMPENSATION Services LPL sponsors various types of advisory programs, including wrap fee programs and mutual fund asset allocation programs. LPL makes these programs available to clients directly and also through third party investment advisor firms (“Advisor”) and their associated persons. This Brochure provides a description of LPL’s Optimum Market Portfolios (“OMP”) program when offered through an Advisor. For more information about LPL’s advisory services and programs other than OMP, please contact your Advisor for a copy of a similar brochure that describes such service or program or go to https://adviserinfo.sec.gov. The OMP program is a professionally managed mutual fund asset allocation program in which LPL and Advisor provide ongoing investment advice. The Advisor obtains the necessary financial data from the client, assists the client in determining the suitability of the program and assists the client in setting an appropriate investment objective. The Advisor, on non-discretionary basis, selects a model portfolio of mutual funds (“Portfolio”) designed by LPL’s Research Department consistent with the client’s stated investment objective. The Portfolios are made up of mutual funds in the Optimum Funds mutual fund family. A Portfolio may include up to six Optimum Funds. LPL has discretion to buy and sell securities in the account and will invest the account based on the Portfolio selected. The client authorizes LPL to take discretion by executing the Account Agreement and Application. LPL rebalances accounts based on the allocations in the Portfolio as described below. LPL reviews the account for rebalancing on the frequency selected by the client at account opening or as altered by the Advisor or the client from time to time. The choices for frequency of rebalancing are quarterly (four times per year), semi-annually (two times per year) or annually (once per year). Accounts are reviewed on the frequency selected based on the anniversary date of account opening, or the next business day closest to the anniversary date, to determine if rebalancing is necessary. An additional rebalance may be requested outside of the scheduled frequency once every 12 months. At each rebalancing review date, accounts are rebalanced if the Account has available cash for investment and at least one of the account positions is outside a range determined by LPL, subject to a minimum transaction amount established by LPL in its discretion. In addition, LPL may review the account for rebalancing in the event that LPL Research changes the model portfolio. LPL invests deposits in an account according to the Portfolio, but such deposits (or a portion thereof) may be liquidated and the proceeds may remain in cash until certain conditions are met related to trade size and positive deviation from the target allocation. Although OMP accounts are not considered tax efficient or tax managed, LPL may delay placing transactions on non- retirement accounts by one day for any rebalancing scheduled to occur on the first one year anniversary date of the account opening in an attempt to limit the tax treatment of realized short-term gains for any position being sold. Liquidation requests in connection with withdrawals and requests related to changes in the Portfolio selected may take up to 5-7 days to process, and, in certain circumstances, may take longer. LPL may also apply discretion to deviate from the model portfolios in accounts, in which it is not possible or impractical to be invested in all of a model’s holdings, for example in smaller accounts. In connection with the program, LPL also acts as custodian to accounts, provides research information to Advisor, provides brokerage services as the broker-dealer on transactions, and performs administrative services, such as performance reporting to clients. Fee Schedule Clients in the OMP program pay LPL and Advisor an annualized fee (“Account Fee”) for the asset management services of LPL and Advisor, as well as the administrative and custodial services of LPL. The Account Fee is shared with Advisor. The Account Fee is negotiable between the client and the Advisor and is based on the value of assets in the account, including cash holdings, and payable quarterly in advance. The maximum Account Fee is 2.50%. Upon request, the Account Fee also may be structured on a tiered basis, with a reduced percentage rate based on reaching certain thresholds. LPL reserves the right to increase the upper limit of the Advisory Fee and/or Manager Fee range(s) upon 30 days’ prior notice to clients. LPL, Advisor and IARs do not charge performance-based fees to accounts in the OMP program. LPL may retain a portion of the Account Fee for its administrative and custodial services. LPL shares up to 100% (typically between 90% to 100%) of the remaining portion of the Account Fee with the Advisor based on the agreement between LPL and Advisor. A 1 2 – E Q H – 1 0 2 5 P a g e 2 L P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS - PROGRAM BROCHURE How the Account Fee is Charged LPL deducts the Account Fee and other fees and charges associated with an OMP account from the account. LPL calculates and deducts the Account Fee in the method described in the Account Agreement, unless other arrangements are made in writing. If a client wishes to be billed for the Account Fee, rather than a deduction directly from the account, the client needs to make a request to LPL through the Advisor. Payment in Advance and Refund of Pre-Paid Fees LPL deducts the Account Fee quarterly in advance. If the Account Agreement is terminated before the end of the quarterly period, LPL will pay the client a prorated refund of any pre-paid quarterly Account Fee based on the number of days remaining in the quarter after the termination date. However, if the account is closed within the first six months by the client or as a result of withdrawals that bring the account value below the required minimum, LPL and Advisor reserve the right to retain the pre- paid quarterly Account Fee for the current quarter in order to cover the administrative costs of establishing the account (for example, the costs related to transferring positions in and out of the account, data entry in opening the account, reconciliation of positions in order to issue performance information, and re-registration of positions). After the termination date, LPL may convert the account to a brokerage account. In a brokerage account, client is charged a commission for each transaction and LPL and Advisor have no responsibility to provide ongoing investment advice. Other Types of Direct Fees and Expenses of LPL In addition to the Account Fee, LPL assesses a transaction charge of $5 on each purchase and sale transaction. The transaction charge is identified under the service charge column on trade confirmations and represents a payment for expenses associated with trade execution and processing, including preparing, printing and/or delivering confirmations. Transaction charges are waived if eligible contribution within the previous 365 days, including transfers, wires, checks, ACH or journal, are made to the account. Transaction charges present conflicts of interest. For example, where transaction charges apply, the more transactions Client enters into, the more compensation LPL receives. The transaction charge may be higher or lower than commissions otherwise payable in the absence of the Account Fee. When an investment change is made to the account (e.g., for transactions resulting from contributions, rebalancing, model changes, and withdrawals), the transaction charge can represent a meaningful cost to Client, in particular, at smaller account sizes. LPL does not share any portion of the transaction charge with Advisor. Clients also pay LPL other additional miscellaneous administrative or custodial-related fees and charges that apply to an OMP account. LPL notifies clients of these charges at account opening and makes available a current list of these charges on its website at lpl.com/disclosures.html. These transaction charges and other direct fees are not directly based on the costs of the transaction or service by LPL, often include a profit to LPL, and certain of the fees are lowered or waived for certain clients. Fees Charged by Third Parties, Including the Optimum Funds There are other fees and charges that are imposed by third parties other than LPL that apply to investments in OMP accounts. In OMP, assets are invested in mutual funds and, therefore, there are two layers of advisory fees and expenses for those assets. As a shareholder of a Fund, Client will pay an advisory fee to the investment advisor of the Optimum Funds and other expenses charged by the Fund. Client will also pay LPL and Advisor the Account Fee with respect to assets invested in the Funds. The Optimum Funds or funds with similar investment objectives may be purchased directly outside of the Program. Therefore, clients could generally avoid the second layer of fees by not using the advisory services of LPL and Advisor and by making their own decisions regarding mutual fund investing. The amount of the advisory fees and other expenses of the Optimum Funds are set out in the prospectus and financial statements of the Optimum Funds, which are available upon request from Advisor or the Optimum Funds directly. Clients should understand that in many cases the mutual funds and mutual fund share classes offered through the Program charge higher fees and expenses than those that are not offered through the Program, and such other mutual funds and share classes may be equally or more appropriate for a client’s account. As discussed below, Client should understand that a portion of the fees and expenses Client pays as a shareholder of the Optimum Funds is used by the sponsor of the Funds to pay LPL for A 1 2 – E Q H – 1 0 2 5 P a g e 3 L P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS - PROGRAM BROCHURE services LPL provides with respect to the funds. See Item 9, “Participation or Interest in Client Transactions,” for more information on the payments received by LPL with respect to the Optimum Funds. Other financial services firm may offer the same mutual funds that are offered through the Program but at lower overall costs to investors than the costs that clients incur by investing through the Program. Advisor may charge fees in addition to the Account Fee. Clients should refer to the Firm Brochure of Advisor for more information regarding fees charged by Advisor. If client transfers into an OMP account a previously purchased mutual fund, and there is an applicable contingent deferred sales charge on the fund, client will pay that charge when the mutual fund is sold. If the account is invested in a mutual fund that charges a fee if a redemption is made within a specific time period after the investment, client will be charged a redemption fee. Depending on the share class and fee structure of the previously purchased mutual fund, LPL can receive fees such as 12b-1 fees from the previously purchased mutual fund until the position is liquidated and subsequently invested according to the OMP model. Any 12b-1 fees paid to LPL by mutual funds transferred into an account will be credited to the client’s account. If a mutual fund has a frequent trading policy, the policy can limit a client’s transactions in shares of the fund (e.g., for rebalancing, liquidations, deposits or tax harvesting). Decisions regarding the sale of mutual funds in an account may be made by LPL without regard to whether a client will be assessed a redemption fee. Clients can find more information regarding the fees and expenses of a mutual fund or ETF in the fund’s prospectus, which is available upon request from the IAR or directly from the fund. When transferring securities into an OMP account, client should be aware that certain securities are not be eligible for the account. In such case, the securities may be rejected, sold after the transfer, or moved to a brokerage account. Note that when an ineligible security is transferred into an account and subsequently sold or moved to a brokerage account, the advisory fee will be charged on such asset for the period of time the security was held in the account. Client should be aware that securities transferred into an account may have been subject to a commission or sales load when the security was originally purchased. After transfer into an OMP account, client should understand that an advisory fee will be charged based on the total assets in the account, including the transferred security. When transferring securities into an account, client should consider and speak to IAR about whether: a commission was previously paid on the security; client wishes for the security to be managed as part of the account and be subject to an advisory fee; or client wishes to hold the security in a brokerage account that is not managed and not subject to an advisory fee. • • • Important Things to Consider About Fees on an OMP Account type and size of the account • The Account Fee is a single fee for investment advisory services and other administrative and custodial services. Clients do not pay a commission to LPL but do pay a transaction charge (unless waived) as described above. The Account Fee may cost the client more than purchasing the program services separately, for example, paying an advisory fee plus commissions to a broker-dealer for each transaction in the account. Factors that bear upon the cost of the account in relation to the cost of the same services purchased separately include the: • • historical and or expected size or number of trades for the account, and • number and range of supplementary advisory and client-related services provided to the client. • The Account Fee may be higher than the fees charged by other investment advisors for similar services. This is the case in particular if the Account Fee is at or near the maximum Account Fee set out above. The Advisor is responsible for determining the Account Fee to charge each client based on factors such as total amount of assets involved in the relationship and the complexity, number and range of supplementary advisory and client-related services to be provided to the account. Clients should consider the level and complexity of the advisory services to be provided when negotiating the Account Fee with Advisor. • The Advisor and its IARs recommending the program to the client receives compensation as a result of the client's participation in the program. This compensation includes a portion of the Account Fee and also may include other compensation, such as bonuses, awards or other things of value offered by LPL to Advisor or by LPL or Advisor to the IAR. For example, LPL may pay a bonus to Advisor or its IARs in the form of reimbursement of fees that Advisor or its IARs pay to LPL A 1 2 – E Q H – 1 0 2 5 P a g e 4 L P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS - PROGRAM BROCHURE for administrative services. In particular, pursuant to the agreement between LPL and Advisor, LPL pays Advisor an amount, in addition to a percentage of the client's Account Fee, based on the current market value of all client assets Advisor maintains in LPL advisory programs, including the OMP program. This amount is paid from the portion of the fee retained by LPL, and payment of this amount does not result in any higher or additional client fees. Therefore, this additional portion of the fee provides Advisor a greater financial benefit if more client assets are invested in LPL advisory programs. The amount of compensation that Advisor receives from LPL may be more or less than what the Advisor and its IARs would receive if the client participated in other LPL programs, programs of other investment advisors or paid separately for investment advice, brokerage and other client services. Therefore, the Advisor and its IARs may have a financial incentive to recommend a program account over other programs and services. • The investment products available to be purchased in the program can be purchased by clients outside of an OMP account, through broker-dealers or other investment firms not affiliated LPL. • Clients should consider the impact of fees and expenses on their investment portfolio, as described in the informational brochure titled “How Fees and Expenses Affect Your Portfolio” on lpl.com/disclosures.html under “Investor Regulatory & Educational Resources.” ITEM 5 ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS LPL generally requires a minimum account value of $1,000, but eligible contribution within the previous 365 days, including transfers, wires, checks, ACH or journal, are required for account sizes below $10,000. In certain instances, LPL will permit a lower minimum account size. An account will not be invested according to the Portfolio until the minimum has been reached. The program is available for individuals, individual retirement accounts (“IRAs”), banks, thrift institutions, credit unions, pension and profit sharing plans, including plans subject to Employee Retirement Income Security Act of 1974 (“ERISA”), trusts, estates, charitable organizations, state and municipal government entities, corporations and other business entities. ITEM 6 PORTFOLIO MANAGER SELECTION AND EVALUATION In OMP, LPL does not select, review or recommend the services of other investment advisor or portfolio management firms. LPL and Advisor are responsible for the investment advice and management offered to clients, and the client selects the Advisor who services the account. Advisor is responsible for determining the standards required for its associated persons. For more information about the Advisor, client should refer to the Advisor’s Firm Brochure, which client should have received at the time client opened the account. In OMP, clients invest in Portfolios designed by LPL’s Research Department. LPL Research designs different types of Portfolios for OMP to meet the varying needs of clients. The Advisor, or the client with the assistance of the Advisor, selects the Portfolio and provides advice based on the client’s individual needs. LPL’s Research Department uses the following investment strategies in designing Portfolios. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. Each of these investment strategies seek to generate capital appreciation while assuming a reasonable amount of risk. • Standard. These Portfolios invest in up to six Optimum Funds across the following asset classes: large growth, large value, small/mid growth, small/mid value, international, and fixed income. • U.S. These Portfolios invest in up to five Optimum Funds across the following asset classes: large growth, large value, small/mid growth, small/mid value, and fixed income. These Portfolios do not invest in international. • Growth Tilt. These Portfolios invest in up to six Optimum Funds across the following asset classes: large growth, large value, small/mid growth, small/mid value, international, and fixed income. These Portfolios are over-weighted to growth relative to the standard models. • Value Tilt. These Portfolios invest in up to six Optimum Funds across the following asset classes: large growth, large value, small/mid growth, small/mid value, international, and fixed income. These Portfolios are over-weighted to value relative to the standard models. For Standard and U.S. Portfolios described above, LPL Research makes available a strategic or tactical version for each Portfolio. The strategic Portfolios are intended to take advantage of market opportunities that will occur or persist over a three-to-five-year time A 1 2 – E Q H – 1 0 2 5 P a g e 5 L P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS - PROGRAM BROCHURE frame. The tactically managed Portfolios are intended to take advantage of short-, medium-, or long-term opportunities. In addition, for the Standard Portfolios there are two different versions of the tactically-managed portfolios: Traditional Standard and Spectrum Standard. The asset allocation of the Traditional Standard Portfolios is set primarily leveraging the LPL Research macroeconomic views. The asset allocation of the Spectrum Standard Portfolios is set primarily leveraging the LPL Research diligence views. Types of Investments and Risks Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some risks associated with investing. • Market Risk. This is the risk that the value of securities owned by an investor may go up or down, sometimes rapidly or • unpredictably, due to factors affecting securities markets generally or particular industries. Interest Rate Risk. This is the risk that fixed income securities will decline in value because of an increase in interest rates; a bond or a fixed income fund with a longer duration will be more sensitive to changes in interest rates than a bond or bond fund with a shorter duration. • Economic Conditions Risk. This is the risk that economic, political or financial developments will, from time to time, result in periods of volatility or other adverse effects that could negatively impact your account. • Credit Risk. This is the risk that an investor could lose money if the issuer or guarantor of a fixed income security is unable • or unwilling to meet its financial obligations. Investment Company Risk. To the extent a client account invests in ETFs or other investment companies, its performance will be affected by the performance of those other investment companies. Investments in ETFs and other investment companies are subject to the risks of the investment companies’ investments, as well as to the investment companies’ expenses. If a client account invests in other investment companies, the client account may receive distributions of taxable gains from portfolio transactions by that investment company and may recognize taxable gains from transactions in shares of that investment company, which would be taxable when distributed. • Pledging Assets. LPL has partnered with certain banks to help facilitate clients’ access to collateralized non-purpose lines of credit; however, clients are not required to use the banks in LPL’s program, and can work directly with other banks (“non- partner banks”) to negotiate loan terms or obtain other financing arrangements. Clients who choose to use non-partner banks should notify Advisor of the amount of the line of credit. In these collateralized lending arrangements, clients borrow from the bank and pay interest to the bank. In some cases, Advisor, through IAR, may recommend that a client seeking to access funds (for purposes other than purchasing securities) hold his securities investments and instead utilize a non- purpose line of credit collateralized by the assets in his advisory account. Unless Advisor, through IAR, specifically recommends that a client hold his securities investments and instead utilize a collateralized line of credit to access funds, the decision regarding whether to arrange for a collateralized loan and the decision to draw down on such a loan are not covered by a client’s advisory relationship with LPL or Advisor. While Advisor, through IAR, may assist the client with facilitating a line of credit, clients are responsible for independently evaluating the terms of the loan and deciding whether the loan meets their needs. Clients also should be aware that pledging assets in an account to secure a loan involves additional risks. The bank holding the loan has the authority to liquidate all or part of the securities at any time without your prior notice in order to maintain required maintenance levels, or to call the loan at any time. As a practical matter, this may cause you to sell assets and realize losses in a declining market. Moreover, the ability of Advisor and IAR to make recommendations for the account may be restricted by collateral requirements imposed by the bank. These restrictions or a forced liquidation may interfere with your long term investment goals and/or result in adverse tax consequences. Further, you should note that the returns on accounts or on pledged assets may not cover the cost of loan interest and advisory fees. Clients should be aware that LPL’s collateralized loan program is one way, among many, for clients to raise necessary cash. Before pledging assets in an account, clients should carefully review the loan agreement, loan application and any forms required by the bank and any other forms and disclosures provided by LPL. For a list of the banks currently participating in LPL’s collateralized lending program, please visit lpl.com/disclosures.html, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Third Party Compensation and Related Conflicts of Interest.” A 1 2 – E Q H – 1 0 2 5 P a g e 6 L P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS - PROGRAM BROCHURE • Cybersecurity Risk. Failures or breaches of the electronic systems of LPL, its service providers, securities market participants or the issuers of securities can cause significant losses for investors. Unintentional cyber events, such as the inadvertent release of confidential information, could also adversely impact investor account. Any cyber event could cause result in the loss or theft of investor data or cause investors financial loss and expense. • Use of Artificial Intelligence and Machine Learning. Recent technological advances in artificial intelligence, generative artificial intelligence, and machine learning technology (collectively, “Machine Learning Technology”) may pose risks to LPL and Advisor. LPL and Advisor could be further exposed to the risks of Machine Learning Technology if third-party service providers or any counterparties, whether or not known to LPL or Advisor, also use Machine Learning Technology in their business activities. LPL and Advisor will not be in a position to control the operations of third-party service providers or counterparties, the manner in which third-party products are developed or maintained or the manner in which third-party services are provided. Machine Learning Technology is generally highly reliant on the collection and analysis of large amounts of data, and it is not possible or practicable to incorporate all relevant data into the model that Machine Learning Technology utilizes to operate. Certain data in such models will inevitably contain a degree of inaccuracy and error, potentially materially so, and could otherwise be inadequate or flawed, which would be likely to degrade the effectiveness of Machine Learning Technology. To the extent that LPL or Advisor are exposed to the risks of Machine Learning Technology, any such inaccuracies or errors could have adverse impacts on LPL or Advisor, as applicable. Machine Learning Technology and its applications, including in the financial services sector, continue to develop rapidly, and it is impossible to predict the future risks that will from time to time arise from such developments. • Values-Based and Environmental, Social and Governance (ESG) Investing Risk. Values-based investing or ESG investing, also known as “socially responsible investing,” “sustainable investing,” or “impact investing,” focuses on the social values or environmental, social, and governance standards or the sustainability factors of an investment. Some values-based investing strategies focus on factors relating to an individual investor’s personal or religious values, such as “biblical investing,” while other strategies focus on issues like environmental impact. Some values-based investment strategies use values-based criteria to supplement financial analysis when considering a particular issuer or security, while others affirmatively select “socially responsible” investments or screen out or exclude investments in companies that engage in certain activities. Values-based investing may limit the type and number of investments available in a strategy and cause the strategy to underperform other strategies without a values-based focus or with a focus that involves a different type of focus or screening methodology. Values-based strategies may underperform the market as a whole. Companies and issuers selected in a values-based strategy may not or may not continue to demonstrate values-based characteristics. Different investors likely have different opinions about what types of investments are socially responsible. Voting Client Securities Unless a client instructs otherwise, effective November 24, 2025, LPL will vote proxies in accordance with its proxy voting policies and procedures then in effect, which will include engaging one or more third party proxy advisor vendors to make proxy voting recommendations and handle the administrative functions of voting proxies. For OMP, LPL’s proxy voting policies and procedures state that LPL will vote proxies in all instances in accordance with recommendations from Glass, Lewis & Co., a third-party proxy advisory services company, for any securities held in your account, except to the extent otherwise prohibited by law. For the avoidance of doubt, in the event that Glass, Lewis & Co. does not provide a recommendation, LPL will abstain from voting in that proxy campaign. Notwithstanding the foregoing, if Client is a plan subject to ERISA (as defined above), LPL shall vote client proxies in accordance with LPL’s obligations under ERISA and applicable Department of Labor Regulations. Client may expressly retain the right and obligation to vote any proxies or exercise any voluntary corporate actions relating to securities held in the Account, provided Client provides prior written notice to LPL. A copy of LPL’s proxy voting policies is available upon request to LPL. A client can obtain information about how LPL voted with respect to securities held in the client’s account by contacting LPL. Advisor has no role in voting Client proxies and does not provide advice on proxy voting matters or specific proxy solicitations. If a client elects to retain the right and obligation to vote proxies and receive mutual fund shareholder reports, LPL is reimbursed by the proxy issuer or mutual fund for the delivery costs to send proxies and shareholder reports to the client. The A 1 2 – E Q H – 1 0 2 5 P a g e 7 L P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS - PROGRAM BROCHURE maximum fee that can be charged for delivery is set by New York Stock Exchange (NYSE) rules. If LPL uses a vendor to perform the delivery, the vendor seeks reimbursement from the proxy issuer or mutual fund on LPL’s behalf and in certain cases remits a portion of the reimbursement to LPL. If clients have questions regarding the solicitation, they should contact the contact person that the issuer identifies in the proxy materials or their Advisor. In addition, LPL and Advisors do not accept authority to take action with respect to legal proceedings relating to securities held in the account. ITEM 7 CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS The Advisor obtains the necessary financial data from the client and assists the client in setting appropriate investment objectives for the account. The Advisor obtains this information by having the client complete an Account Application which is a part of the Account Agreement. In quarterly communications, LPL asks clients to contact the Advisor if there have been any changes in the client’s financial situation or investment objectives or if they wish to impose any reasonable restrictions on the management of the account or reasonably modify existing restrictions. Clients should understand that the investment objective selected for the program in the Account Application is an overall objective for the entire account and may be inconsistent with a particular holding and the account’s performance at any time. Client also should be aware that achievement of the stated investment objective is a long-term goal for the account. ITEM 8 CLIENT CONTACT WITH PORTFOLIO MANAGERS LPL does not place any restrictions on a clients’ ability to contact and consult with Advisors. ITEM 9 ADDITIONAL INFORMATION Disciplinary Information LPL entered into a settlement with the SEC in which the SEC found that LPL willfully violated its obligations under Section 17(a) of the Exchange Act and Rule 17a-8 thereunder, which require broker-dealers to comply with certain anti-money laundering (“AML”) requirements. The SEC found that LPL did not follow its AML policies for its customer identification program and ongoing customer due diligence obligations by, among other things, not properly verifying new accounts; not timely closing accounts that did not pass its screening measures; and not closing or restricting certain accounts that were prohibited under LPL’s AML Policies. The SEC censured LPL and ordered LPL to cease and desist from committing or causing any violations and any future violations of such section and rule, to pay a civil monetary penalty in the amount of $18 million, and to comply with certain undertakings (2025). LPL entered into a settlement with the SEC in which the SEC found that LPL willfully violated Section 17(a) of the Exchange Act and Rule 17a-4(b)(4) thereunder and Section 204 of the Advisers Act and Rule 204-2(a)(7) thereunder in connection with the maintenance and preservation of off-channel communications; and failed to reasonably supervise its personnel within the meaning of Section 15(b)(4)(E) of the Exchange Act and Section 203(e)(6) of the Advisers Act. LPL admitted to the facts in the settlement order and acknowledged its conduct violated the federal securities laws. The SEC ordered LPL to cease and desist from committing or causing any violations and any future violations of Section 17(a) of the Exchange Act and Rule 17a-4(b)(4) thereunder and Section 204 of the Advisers Act and Rule 204-2(a)(7) thereunder, censured it for its conduct, ordered it to pay a civil monetary penalty in the amount of $50,000,000, and ordered it to comply with certain undertakings (2024). LPL entered into a settlement with the SEC in connection with LPL’s failure to comply with its Customer Identification Program procedures. The SEC found that LPL willfully violated Section 17(a) of the Exchange Act and Rule 17a-8 thereunder and was a cause of a third party’s violations of Sections 17(a)(2) and (3) of the Securities Act and Section 206(2) of the Advisers Act. The SEC ordered LPL to cease and desist from committing or causing any further violations of these laws and regulations, censured LPL for its conduct, and ordered the payment of disgorgement and prejudgment interest totaling $141,202 (deemed satisfied based on LPL’s voluntary remedial payment of $4,118,876 to the impacted client), and the payment of a civil money penalty of $750,000 (2021). As part of a voluntary self-reporting initiative in 2019, LPL entered into a settlement with the SEC in which the SEC found that LPL willfully violated Section 206(2) and 207 of the Investment Advisers Act of 1940 (the “Advisers Act”) in connection with inadequate disclosure to clients of its and its associated persons’ conflicts of interest related to its receipt of 12b-1 fees and/or A 1 2 – E Q H – 1 0 2 5 P a g e 8 L P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS - PROGRAM BROCHURE its selection of mutual fund share classes that pay such fees. The SEC ordered LPL to cease and desist from committing or causing any violations of Sections 206(2) and 207 of the Advisers Act, censured it for its conduct, and ordered the payment of disgorgement and prejudgment interest to affected investors totaling $9,333,516 (2019). LPL, as a broker-dealer, is a member of (“FINRA”) and has found to be in violation of FINRA’s rules related to its brokerage activities. In particular, LPL consented to sanctions related to the following matters: • • • • • • • • • • LPL’s supervisory systems and maintenance of books and records relating to brokerage direct business transactions, supervisory systems and misstatements about fees relating to brokerage product switch transactions, and supervisory systems relating to brokerage recommendations of publicly traded securities of business development companies (BDCs) to customers, resulting in a censure, a fine of $5.5 million, restitution to impacted customers, and an undertaking to certify that LPL has remediated the systems and procedures for making recommendations of BDCs (2023). LPL’s supervisory systems and procedures relating to the transmittal of customer funds by wire or check to third parties and maintenance of related books and records, resulting in a censure, a fine of $3,000,000, restitution to impacted clients, and an undertaking to identify and pay restitution to affected customers for certain other improper transfers (2023). LPL’s failure to accurately calculate its customer reserve requirement, failure to maintain a sufficient customer reserve, failure to maintain policies and procedures reasonably designed to achieve compliance with the Securities and Exchange Act and FINRA rules, and failure to maintain accurate books and records, resulting in a censure and a fine of $300,000 (2022). LPL’s self-reporting of potential issues related to certain C-share purchase suitability reviews and its supervisory systems and procedures relating to waivers of front-end sales charges for rollovers of 529 savings plan investments from one state plan to another, resulting in a censure and payment of restitution to impacted customers (2021). LPL’s supervisory systems and procedures relating to record retention, fingerprinting and screening of certain associated persons, and supervision of consolidated reports, resulting in a censure, a fine of $6,500,000 and an undertaking to review and enhance related policies, systems and procedures (2020). LPL’s supervisory systems and procedures relating to changes in the authority of custodians of accounts established under the Uniform Gifts to Minors Act and/or the Uniform Transfers to Minors Act, resulting in a censure, a fine of $300,000, and an undertaking to review and enhance its policies, systems, and procedures related to supervision of such accounts (2019). • The effectiveness of LPL’s anti-money laundering program, LPL’s failure to amend certain Forms U4 and U5, and LPL’s systems and supervisory procedures relating to Forms U4 and U5 reporting requirements, resulting in a censure and a fine of $2,750,000 and an undertaking to review the process used to disclose customer complaints on Forms U4 and U5 (2018). LPL’s brokerage supervisory and disclosure procedures related to the sale of certain brokered certificates of deposit in brokerage accounts, resulting in a censure and a fine of $375,000 (2018). LPL’s systems and supervisory procedures relating to the creation and distribution of certain required account notices, resulting in a censure, a fine of $900,000, and an undertaking to review affected processes (2016). LPL’s systems and supervisory procedures relating to the format in which certain electronic records were retained, resulting in a censure and a fine of $750,000 (2016). LPL’s various brokerage supervisory procedures, including those related to the sale of complex non-traditional ETFs, variable annuity (“VA”) contracts, real estate investment trusts (“REITs”) and other products in brokerage accounts, as well as LPL’s failure to monitor and report trades and deliver trade confirmations, resulting in a censure and a fine of $10,000,000, and restitution of $1,664,592 (2015). LPL, as a broker-dealer, is regulated by each of the 50 states and has been the subject of orders related to the violation of state laws and regulations in connection with its brokerage activities. In particular, LPL entered into consent orders related to the following matters: • • LPL’s supervision of electronic signature practices at an LPL branch office in Massachusetts, resulting in a fine of $250,000 and an undertaking to conduct an internal review of certain related policies and procedures (Massachusetts or “MA”, 2023). LPL’s supervision of an LPL broker-dealer/investment adviser agent’s sales of structured products, resulting in a censure, an offer of restitution to impacted clients, and a fine of $125,000 (Texas, 2022). A 1 2 – E Q H – 1 0 2 5 P a g e 9 L P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS - PROGRAM BROCHURE • • • • LPL’s supervision of two LPL broker-dealer and/or investment adviser agents who pled guilty to charges of fraudulent practices with LPL customers, resulting in a cease and desist order, a fine of $350,000 and a $150,000 contribution for financial literacy and investor education initiatives, training and related materials (Connecticut, 2021). LPL’s supervision of an LPL representative under a heightened supervision plan, resulting in a cease and desist order; a fine of $275,000; payments of restitution, disgorgement and investigative costs; and offers of payment of surrender charges in connection with variable annuity contracts for impacted customers (New Hampshire or “NH”, 2020). LPL’s failure to timely register (or maintain the registration of) certain agents in MA and failure to amend Forms U4 and U5 for certain agents registered in MA, resulting in a censure, a fine of $1,100,000, and an undertaking to review and enhance its policies and procedures related to registering its agents in MA and filing reportable events (MA, 2019). LPL’s brokerage supervisory procedures relating to email review and annual branch office examinations, resulting in a civil penalty of $450,000 and an undertaking for third-party review of related processes (Indiana, 2018). • The sale of unregistered, non-exempt securities in violation of state registration requirements, resulting (upon entry of the individual consent order) in payment to each participating state or jurisdiction of a civil penalty of $499,000, reimbursement of certain investigative expenses, remediation through repurchase of certain securities and payment of losses to certain affected customers, and certain additional undertakings (Settlement with up to 53 members of the North American Securities Administrators Association (NASAA), 2018). • • • The sale of non-traded alternative investments in excess of prospectus standards or LPL’s internal guidelines and the maintenance of related books and records, resulting in a censure, a fine of $950,000, a $25,000 contribution to an investor education fund and remediation of losses to impacted customers (New Jersey, 2017). LPL’s supervisory practices for LPL representatives located on the premises of a credit union, resulting in a censure, a fine of $1,000,000, and an undertaking to avoid investor confusion specific to the name under which the credit union does business and review LPL’s related policies and procedures (MA, 2017). LPL’s oversight of certain VA transactions, resulting in a censure, a fine of $975,000, restitution to clients and former clients of an LPL representative, disgorgement of commissions retained by LPL in connection with such representative’s VA sales, and an undertaking to review such representative’s brokerage and advisory activities and LPL’s related policies and procedures (MA, 2017). • The sale in brokerage accounts of non-traded REITs in excess of prospectus standards, state concentration limits or LPL’s internal guidelines, resulting in an aggregate civil penalty of $1,425,000, reimbursement of certain investigative expenses and remediation of losses to impacted customers (Global settlement with certain members of NASAA, 2015). • The sale of non-traded REITs in excess of prospectus standards, state concentration limits or LPL’s internal guidelines, resulting in an administrative fine of $250,000, reimbursement of investigative costs of $250,000, a $250,000 contribution to an investor education fund and remediation of losses to impacted customers (NH, 2015). • The sale of leveraged and inverse leveraged ETFs (“Leveraged ETFs”), resulting in an administrative fine of $50,000 (Delaware), a penalty of $200,000 (MA), restitution to Delaware customers in an amount up to $150,000, restitution to MA customers in an amount up to $1,600,000, and an agreement to make certain changes in its supervisory system with respect to Leveraged ETFs (2015). • Failure to implement procedures related to the use of senior-specific titles by LPL representatives as required under MA law, resulting in a censure and a fine of $250,000 (2015). For more information about those state events and other disciplinary and legal events involving LPL and its IARs, client should refer to Investment Adviser Public Disclosure at https://adviserinfo.sec.gov/ or FINRA BrokerCheck at https://brokercheck.finra.org/. A 1 2 – E Q H – 1 0 2 5 P a g e 1 0 L P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS - PROGRAM BROCHURE Other Financial Industry Activities and Affiliations LPL is a broker-dealer registered with FINRA and the SEC. As a broker-dealer, LPL transacts business in various types of securities, including mutual funds, stocks, bonds, commodities, options, private and public partnerships, variable annuities, real estate investment trusts and other investment products. LPL is registered to operate in all 50 states and has primarily an independent- contractor sales force of registered representatives and investment adviser representatives dispersed throughout the United States. LPL has a dedicated team of employee IARs in its offices who service certain accounts, and also a small subset of IARs who operate their own offices or are located on the premises of certain financial institutions and are employees of LPL Employee Services, LLC, an LPL-affiliated company. LPL is also registered as an introducing broker with the Commodity Futures Trading Commission. In addition, LPL is qualified to sell insurance products in all 50 states. Associated persons of Advisor may also be broker-dealer registered representatives of LPL or another broker-dealer. If an associated person of Advisor is a broker-dealer registered representative of LPL, that person is providing advisory services to the program account on behalf of Advisor. That person is not acting in a broker-dealer capacity or on behalf of LPL with respect to the services provided under the program. LPL also contracts with other advisors to make the program available to clients through the other advisor firms. In such case, LPL and the other advisor firms share in the Account Fee. LPL Enterprise, LLC (“LPLE”), is a registered broker-dealer and related person of LPL. LPLE became a registered investment adviser in August Our affiliate, LPLE, is an investment adviser registered with the SEC and a broker-dealer registered with FINRA and the SEC. As a broker-dealer, LPLE transacts business in various types of securities, including mutual funds, stocks, bonds, commodities, options, private and public partnerships, variable annuities, REITs and other investment products. LPLE is registered to operate in all 50 states and has primarily an independent-contractor sales force of registered representatives and investment advisor representatives dispersed throughout the United States. If required for their positions with a registered broker-dealer, LPLE’s principal executive officers are securities licensed as registered representatives of LPL. In addition, LPLE is qualified to sell insurance products in all 50 states. LPL and The Private Trust Company, N.A. (“PTC”), a federally chartered non-depository bank licensed to provide trust services in all 50 states, are related persons. PTC serves as IRA custodian for program accounts set up as IRAs and receives an annual maintenance fee for this service. PTC also provides personal trustee services to clients for a variety of administrative fiduciary services, which services may relate to a program account. Because LPL and PTC are affiliated companies and share in revenues, there is a financial benefit to the companies if a client uses PTC as a custodian or for personal trustee services, or if a PTC client uses LPL as an investment advisor. PTC’s IRA custodian and trustee services and related fees are established under a separate engagement between the client and PTC. Fiduciary Trust Company of New Hampshire (“FTC”), a non-depository trust company, is a related person of LPL. FTC provides custodial and various other recordkeeping and services to IRAs and certain employer-sponsored plans maintained through non- OMP Program accounts. Because LPL and FTC are affiliated companies and share in revenues, there is a financial benefit to the companies if a client is referred to or otherwise elects to engage with FTC for services under another LPL program, and uses LPL as the investment advisor or broker-dealer. FTC’s custodial and recordkeeping services and related fees are established under a separate engagement between the client and FTC. Code of Ethics and Personal Trading LPL has adopted a code of ethics that includes guidelines regarding personal securities transactions of its employees and investment adviser representatives (“IARs”). The code of ethics permits LPL employees and IARs to invest for their own personal accounts in the same securities that LPL and IARs purchase for clients in program accounts. This presents a conflict of interest because trading by an employee or IAR in a personal securities account in the same security on or about the same time as trading by a client can disadvantage the client. LPL requires in its code of ethics that LPL employees and LPL IARs report certain personal securities transactions and holdings to LPL. LPL generally has procedures to review personal trading accounts for front- running. However, since LPL’s Research Department has sole control over trading decisions (including timing of implementation A 1 2 – E Q H – 1 0 2 5 P a g e 1 1 L P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS - PROGRAM BROCHURE thereof) for the Model Portfolios in the Program, the potential for front-running by most LPL employees and LPL IARs is limited, and no such review is conducted other than for employees in LPL’s Research Department. In addition, employees in LPL’s Research Department are required to obtain pre-clearance prior to purchasing certain securities for a personal account. Employees and IARs are also required to obtain pre-approval for investments in private placements and initial public offerings. A copy of the LPL code of ethics is available to clients or prospective clients upon request and is available at lpl.com/disclosures.html. Participation or Interest in Client Transactions Purchases of mutual fund shares may be processed through LPL’s proprietary account resulting in such purchases being characterized as principal transactions for certain reporting purposes. In such case, the shares will be purchased at the fund’s net asset value, and no additional charges will be applied to such transactions as a result of LPL’s use of a proprietary account. LPL does not otherwise engage in principal transactions with its clients in the program. LPL’s parent company, LPL Financial Holdings Inc., is a publicly traded company. LPL Financial Holdings Inc. stock may not be purchased directly in OMP accounts. However, an OMP account may include a mutual fund that holds LPL financial Holdings Inc. stock as an underlying investment. LPL provides investment consulting services to the investment advisor of the Optimum Funds. These services include assisting the investment advisor in determining whether to engage, maintain or terminate sub-advisors for the Optimum Funds. As compensation for these services, LPL receives an investment consulting fee of up to 0.22% of assets from the investment advisor to the Optimum Funds. In addition, a senior executive officer of LPL serves as a Trustee of the Optimum Funds. Certain of the Optimum Funds are subject to voluntary expense caps that may result in the adviser to the Optimum Funds waiving fees or reimbursing expenses that exceed those caps. The adviser to the Optimum Funds bears the cost of any reimbursements or waivers. LPL also performs recordkeeping, administrative and shareholder services on behalf of the Optimum Funds and receives compensation for the services based on the amount of Program assets that are invested in the funds (up to 0.15% annually). These services include establishing and maintaining accounts with the Optimum Funds, facilitating settlement of funds, responding to customer inquiries and requests, and maintaining sub-account records reflecting the issuance, exchange or redemption of shares by each program account. The receipt of this recordkeeping and investment consulting compensation by LPL is an important revenue stream and presents a conflict of interest, because LPL has a financial benefit the more assets that are invested in the Optimum Funds. The investment consulting and recordkeeping compensation is retained by LPL and is not shared with Advisors. Although LPL does not share investment consulting and recordkeeping compensation with Advisor or IARs, such fees and payments will increase LPL’s profits and indirectly benefit Advisor or IARs, for example by being used by LPL to support marketing or training costs. In addition, LPL charges a setup fee to product sponsors when adding new investment products or share classes of an investment product to LPL’s investment platforms. In the case of exchange traded products, LPL receives up to $15,000 as a sponsor level due diligence fee, up to $7,500 per fund and up to an additional $15,000 per product for complex ETPs and ETPs. In the case of mutual funds, LPL receives a one-time set up fee of up to $15,000 as a sponsor level due diligence fee and a setup fee of $7,500 per fund. In the case of UITs, LPL charges up to $5,000 per trust. LPL does not share this compensation with Advisor or its IARs. LPL offers product sponsors of mutual funds, closed funds, interval funds, ETFs, alternative investments, advisory strategies, annuities and life insurance contracts the opportunity to purchase analytical data, business intelligence and ad hoc reporting. This information helps product sponsors in their sales, distribution and product development efforts with respect to customers and clients and creates similar conflicts to those discussed above. LPL receives up to $600,000 annually from each product sponsor in third party compensation for this information. A 1 2 – E Q H – 1 0 2 5 P a g e 1 2 L P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS - PROGRAM BROCHURE Cash Sweep Service Options LPL automatically transfers cash balances (including otherwise uninvested cash amounts received from the customer, securities transactions, dividend and interest payments, and other account-related activities) in a customer’s eligible accounts through the account’s designated sweep service option, where applicable. The type of sweep service options available (and how cash is held) depends on the customer’s account type. LPL offers Federal Deposit Insurance Corporation (“FDIC”)-insured bank sweep services for most customer accounts. Accounts may be eligible for the LPL Insured Cash Account (“ICA”) Program, the LPL Deposit Cash Account (“DCA”) Program or the money market mutual fund sweep, each described below. Not all sweep service options are available to all types of customer accounts. Cash sweep is offered as an account feature and service to facilitate the operation and maintenance of the account and is not intended to be used as an investment option or as part of an account’s asset allocation, though for certain advisory accounts, it is typical for an account to have an allocation to cash to support the operational needs and fees charged to the account. LPL and its financial professionals do not typically recommend specific sweep service options or underlying sweep holdings. For more information, please see your customer agreement and the applicable ICA or DCA disclosure booklet, or the sweep money market fund prospectus. The aggregate fees and expenses received by LPL in connection with the customer account’s designated sweep service option can be higher or lower than the customer’s yields on the sweep service option depending on the particular sweep option, prevailing interest rates and other market factors. See https://www.lpl.com/disclosures/lpl-financial-fdic-insured-bank-deposit- sweep-programs.html for Information about our customer fees and customer Interest rates for ICA and DCA, or contact your financial professional for information about our customer fees and customer interest rates for money market funds. Historically, customer yields in ICA have always been lower than the aggregate fees and charges received by LPL. Customer yields in DCA and in money market mutual funds have been both lower and higher than the aggregate fees and charges received by LPL. Cash sweep services are not intended to be used for long-term investments and are more appropriately viewed as an indirect cost of maintaining and operating the account. LPL makes available a wide range of investment alternatives with differing risk and return characteristics, which are better suited for meeting customer investment needs and objectives. Customers should compare the terms, interest rates, required minimum amounts and other features of their account’s applicable sweep service option available through other types of accounts and investment options available in their account. FDIC insurance protects against the loss of FDIC-insured deposits if the depository institution or bank holding the deposit fails. LPL itself is not an FDIC-insured depository institution. With respect to our sweep service options, only balances received by, and deposited at, the ICA and DCA are eligible for FDIC insurance (subject to applicable limits). Eligibility for pass-through deposit insurance coverage for ICA and DCA, deposits is subject to fulfilling specific conditions. Client Cash Accounts and money market mutual funds are not customer bank deposits and are subject to investment risks, including the potential loss of the amount invested. These investments are not FDIC-Insured, but may be subject to SIPC protection. • Insured Cash Account (ICA). LPL's ICA sweep service option automatically sweeps otherwise uninvested cash balances held within customer brokerage (and certain advisory accounts) into interest-bearing bank deposits eligible for FDIC insurance (subject to applicable limits). Under its agreement with each ICA participating bank in which customer cash may be swept, LPL receives a fee from the bank equal to a percentage of the average daily deposit balance held at the bank. Such fees differ among the participating banks depending on the current interest rate environment and/or any fee waivers made by LPL. The fee LPL receives is generally an average aggregate annual rate of up to 6% as applied across the deposits held at all of the ICA participating banks. Because the banks generally pay different amounts to LPL on account balances, fees received by LPL with respect to a specific customer account (and the account's cash holdings) may be higher or lower than this average percentage amount. The fees received by LPL from the ICA participating banks reduce the interest rate customers receive on their cash held through ICA. These fees are additional compensation to LPL for operating and maintaining the account and for LPL’s other services to the account. LPL has chosen to offer ICA as the sole sweep service option for certain account types, in part because of the additional compensation LPL earns from the use of ICA. A 1 2 – E Q H – 1 0 2 5 P a g e 1 3 L P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS - PROGRAM BROCHURE In situations where customer cash balances allocated through ICA exceed the deposit availability at ICA participating banks, uninsured cash balances may be placed into an “overflow” Client Cash Account. Such balances are considered to be “free credit balances” and represent a direct liability of LPL to the customer. See below for information about how LPL is compensated on Client Cash Account balances. • Deposit Cash Account (DCA). LPL's DCA sweep service option automatically sweeps otherwise uninvested cash balances held within certain advisory accounts into interest bearing bank deposits eligible for FDIC Insurance (subject to applicable limits). In the DCA program, each Bank pays compensation equal to a percentage of the average daily aggregated omnibus deposit balance held at the bank. This amount includes the fee for the third-party administrator, LPL’s per account fee, and interest payable to participating accounts. Such fees differ among the participating banks. Customers have no rights to the amounts paid by the DCA participating banks, except for interest actually credited to the customer account. However, amounts collected from the DCA participating banks during each period, less interest credited, will be allocated on a per-dollar, per-account basis and used to offset each customer’s monthly LPL account fee for providing the sweep services. In addition, part of the payment by the participating banks will be used to compensate the third-party administrator for its services. For its services under the DCA program, including making the platform available, LPL receives a per-account fee each month. The monthly fee is based on a fee schedule indexed to the current Federal Funds Target (FFT) Rate as detailed in the DCA Disclosure Booklet located on lpl.com. The current fee can also be found at lpl.com. It is expected that this fee will be recouped from the DCA participating banks and will not be a fee directly applied to customer accounts. The fee LPL receives under the DCA program does not vary, and is not affected by the actual amounts held in the deposit accounts or in the customer’s account. LPL has chosen to offer DCA as the sole service option for certain account types, in part because of the additional compensation LPL earns from the use of DCA. In situations where customer cash balances in DCA exceed the deposit availability at DCA participating banks, uninsured cash balances may be placed into an “overflow” money market mutual fund. See below for further information about fees generated by cash balances maintained in the DCA “overflow” money market mutual fund. • Client Cash Accounts – ICA Overflow Balances. LPL receives additional compensation and benefits from the customer cash balances maintained in the ICA overflow mechanism, referred to as Client Cash Account, which constitute free credit balances available for LPL use. LPL can use free credit balances to fund its ongoing operations subject to the limitations under SEC Rule 15c3-3. Pursuant to Rule 15c3-3, LPL can (i) deposit free credit cash balances into a segregated deposit account at its banks, thereby earning interest on the Client Cash Account balances deposited, or (ii) invest the cash balances in securities backed by the full faith and credit of the U.S. government, thereby making money on any yield generated by such securities. The amount LPL will earn from these sources will vary based on market forces and the contracts for deposit arrangements that LPL is able to secure with its banks. LPL may use both or either of these vehicles at its sole discretion. Any amounts LPL receives pursuant to these sources will be reduced by the interest payable, if any, to customers on such balances, and further reduced by the cost of borrowing any funds necessary to meet its reserve requirements under Rule 15c3-3. For example, LPL may earn interest or a return by investing in short- term U.S. Government or Agency instruments or by using these balances to fund margin loans to its customers at a lower funding cost than would otherwise be the case. Customers do not share in the returns or proceeds associated with LPL's use or investment of such free credit balances, which are expected to exceed the amount of any Interest paid to the customer for Client Cash Account balances. • Money Market Mutual Fund Sweep Option. For customer accounts not eligible for ICA or DCA, otherwise uninvested cash balances held in the account are automatically swept and invested daily into shares of a money market mutual fund. Currently, taxable and tax-exempt money market funds offered by J.P. Morgan Asset Management and Federated Services Company, are available. LPL receives compensation in the form of servicing fees of up to 0.25% of customer assets invested in J.P. Morgan Asset Management money market funds and up to 0.35% of customer assets invested in Federated Services Company money market funds. These money market mutual funds generally pay higher 12b-1 fees than other money market funds that are not used for sweep services. The 12b-1 fees and the payer of such A 1 2 – E Q H – 1 0 2 5 P a g e 1 4 L P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS - PROGRAM BROCHURE fees are set out in the prospectus of the money market mutual fund. LPL receives service and administrative fees relating to the support of the sweep program from the sponsors of these funds, ranging between 0.25% and 0.45% of the assets Invested In the money market funds. Such fees may be waived by the fund companies in their sole discretion. These payments are in addition to other fees (e.g., recordkeeping and 12b-1 fees) received by LPL, where applicable. LPL also receives fees of up to 0.45% for DCA “overflow” balances that are swept into the Goldman Sachs Asset Management Financial Square Government Fund, if any. The fees and the payer of such fees are set out in the prospectus of the money market fund. The compensation that LPL and Advisor receive related to the ICA, the DCA (including from any ICA and DCA overflow mechanisms) and the Sweep Funds is in addition to the Account Fee received with respect to the assets in the sweep investment. This compensation related to the ICA, the DCA and Sweep Funds is an important revenue stream and presents a conflict of interest because LPL and Advisor have a financial benefit if cash balances are maintained in the ICA, the DCA or funds. However, LPL and Advisor do not take into account this compensation when it makes decisions on a Portfolio’s allocation to cash. Collateralized Lending Arrangements LPL has partnered with certain banks to help facilitate clients’ access to non-purpose lines of credit collateralized by their investment accounts. Because of LPL’s arrangements with the banks participating in the program, clients may be limited in their ability to negotiate the most favorable loan terms. Clients are not required to use the banks in LPL’s program, and can work directly with other banks to negotiate loan terms or obtain other, potentially more favorable, financing arrangements. If a Client obtains a loan from a non-partner bank, he should notify Advisor of the amount of the line of credit. Clients should understand that the interest and additional fees paid to the bank in connection with the loan are separate from and in addition to the advisory fees the client pays LPL for its advisory services on the account. LPL receives third party compensation from participant banks based on the amount of outstanding loans. Compensation can be up to 0.75% of the outstanding loan amount. This compensation to LPL varies, and, therefore, LPL can earn more or less depending on the bank selected by the client. The receipt of compensation poses a conflict of interest to LPL because LPL has a financial incentive for the client to select a bank in the program, and a participating bank that pays LPL more than other participating banks. However, LPL does not share this compensation with Advisor or IAR, and therefore, Advisor and IAR do not have a financial incentive if one bank is selected over another. LPL, Advisor, and IARs have an interest in continuing to receive investment advisory fees, which gives LPL, Advisor, and IARs an incentive to recommend that clients borrow money rather than liquidate some of their assets managed by LPL/Advisor. This incentive creates a conflict of interest for LPL, Advisor, and IARs when advising clients seeking to access funds on whether they should liquidate assets or instead hold their securities investments and utilize a line of credit secured by assets in their account. Because LPL, Advisor, and IARs are compensated primarily through advisory fees paid on clients’ accounts, LPL, Advisor, and IARs also have an interest in managing an account serving as collateral for a loan in a manner that will preserve sufficient collateral value to support the loan and avoid a bank call. This may present a conflict of interest with clients because it could incentivize Advisor or IARs to recommend more conservative, lower performing investments to maintain the stability of the account. For additional disclosures regarding LPL’s collateralized lending program, including a list of the banks currently participating in the program, please visit lpl.com/disclosures.html, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Third Party Compensation and Related Conflicts of Interest.” Credit Cards As part of its cash management services, LPL makes available for its customers credit cards through a partner bank. LPL receives a flat fee for each new activated credit card that is used by the cardholder in the first 90 days. LPL also receives a portion of the transaction volume of the cardholder’s account. LPL’s portion of the transaction volume varies depending on the number of LPL active cardholder accounts. A 1 2 – E Q H – 1 0 2 5 P a g e 1 5 L P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS - PROGRAM BROCHURE Other Clients Client should understand that LPL and Advisor perform advisory and/or brokerage services for various other clients, and that LPL and Advisor may give advice or take actions for those other clients that differ from the advice given to the client. The timing and nature of any action taken for the account may also be different. Review of Accounts LPL provides Advisor and clients with regular written reports regarding their accounts. LPL provides detailed performance information annually describing account performance and positions, with additional information available upon request. In addition, LPL transmits to clients account statements showing transactions, positions, and deposits and withdrawals of principal and income. Portfolio values and returns shown in performance reports for the year-end time period may include mutual fund dividends paid out prior to December 31 but that were posted to the account within the first 2 business days of the subsequent year. The inclusion of such dividends in the year-end performance report may cause discrepancies between the report and the account statement client receives from LPL for the same period. Other Compensation LPL and LPL employees receive additional compensation, business entertainment and gifts from product sponsors. Such compensation may not be tied to the sales of any products or services. Compensation includes such items as gifts valued at less than $100 annually, an occasional dinner or ticket to a sporting event, or reimbursement in connection with educational meetings, customer appreciation events or marketing or advertising initiatives. Product sponsors may also pay for, or reimburse LPL for the costs associated with, education or training events that may be attended by LPL employees and for LPL-sponsored conferences and events. LPL and LPL employees also receive reimbursement from product sponsors for technology-related costs, such as those to build systems, tools and new features to aid in serving customers. LPL employees provide sales support resources to IARs of Advisor that use LPL advisory programs. The compensation that LPL pays to these employees varies based on the assets in LPL’s different advisory programs. These employees have an incentive to promote OMP to IARs of Advisor over other advisory programs. These employees also earn more compensation when IARs of Advisor transition client assets from brokerage accounts to advisory accounts, and have a financial incentive to encourage IARs of Advisor to transition brokerage accounts to advisory. LPL receives compensation in the form of earnings on its short-term investment of cash in program accounts prior to the time the cash is invested for the account. These earnings are generally known as "float." Cash in the account would typically result from contributions to the account or sales of securities in the account. For accounts that opt out of the sweep program, the accounts may remain in free credit balances. In such case, LPL receives compensation in the form of earnings on cash. LPL does not share this compensation with your IAR. In the event a trade error occurs in the Account, and such error is determined to be caused by LPL, LPL typically will cancel the trade and remove the resulting monetary loss to the client from the account. If a trade correction is required as a result of client (e.g., if client does not make full payment for purchases or fails to deliver negotiable securities for liquidations before trade settlement), LPL typically will cancel the trade and any resulting monetary loss will be borne by the client. In the case of a trade that requires a correction as described above and that resulted in a monetary gain to the client, such gain will be removed from the account and can result in a financial benefit to LPL. Financial Information and Custody LPL is a qualified custodian as defined in Rule 206(4)-2 under Advisers Act and maintains custody of OMP client funds and securities in a separate account for each client under the client’s name. LPL as a qualified custodian sends account statements showing all transactions, positions, and all deposits and withdrawals of principal and income. LPL sends account statements periodically when the account has had activity or quarterly if there has been no activity. Clients should carefully review those account statements. A 1 2 – E Q H – 1 0 2 5 P a g e 1 6 L P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS - PROGRAM BROCHURE Brokerage Practices In OMP, LPL requires that clients direct LPL as the sole and exclusive broker-dealer to execute transactions in the account. Clients should understand that not all advisors or program sponsors require their clients to direct brokerage. However, clients should understand that LPL is not paid a commission for executing transactions in OMP accounts and execution is made at the net asset value of the mutual fund. Although LPL is not paid a commission for transactions in the account, LPL charges a $5 transaction charge for each transaction (unless waived as described herein). Because LPL bears costs for each transaction made in an account, this presents a conflict of interest because these costs may be a factor LPL considers when deciding which securities to select and whether or not to place transactions in an account. However, LPL mitigates this conflict by compensating the team responsible for directing the trades through a bonus based on the performance of the portfolios; therefore, the team is not incentivized by cost reduction. LPL will aggregate transactions for a client with other clients. LPL also will aggregate rebalancing transactions for an account with other program accounts. Due to the large number of accounts that may be involved in rebalancing transactions on a single day, LPL may effect transactions for some accounts on one day and for other accounts on the following day or days. In such case, LPL will have discretion to sequence the accounts involved in rebalancing transactions with the goal of treating all accounts equitably over time. LPL will reinvest dividends in accordance with LPL’s Dividend Reinvestment Program (“DRP”). Some securities held in the Account may be ineligible for DRP, including securities not custodied at LPL Financial. There is no requirement to participate in the DRP, Client can enroll or unenroll at any time by contacting their IAR or LPL. DRP transactions will be confirmed on at least a quarterly basis as part of the regular periodic account statement. Additional important disclosures about DRP, including eligibility, fees, how dividends are reinvested, and more can be found at lpl.com/disclosures.html. Certain orders may be blocked or subject to review by LPL before they are directed to an exchange or market maker for execution. This review may result in a delay in execution. LPL reserves the right to place restrictions on your account in our sole discretion, and to cancel any order that we believe would violate federal credit regulations or other regulatory limitations; however, LPL will have no responsibility or liability for failing to cancel any order. ERISA Disclosure LPL provides advisory services under the program as a registered investment adviser under the Investment Advisers Act of 1940. To the extent that LPL has or exercises discretionary authority under the Account Agreement with respect to the management of assets of (or otherwise provides “investment advice” under the Account Agreement as defined under Section 3(21) of ERISA to) a Plan subject to ERISA, LPL will be deemed a “fiduciary” as such term is defined under Section 3(21) of ERISA with respect to such advisory services. Unless specifically agreed to in writing, LPL does not serve as an “investment manager,” as such term is defined under Section 3(38) of ERISA. Brochure Supplements Accompanying this Brochure are Brochure Supplements for individual employees or officers of LPL. Note that although these individuals are responsible for certain investment advice provided by LPL, they are not responsible for the ongoing individualized investment advice provided to a particular client. For more information about the Advisor, client should refer to the Advisor’s Firm Brochure, which should have been provided at the time client opened the account. If client did not receive Advisor’s Firm Brochure, the client should contact the Advisor. A 1 2 – E Q H – 1 0 2 5 P a g e 1 7 L P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS March 31, 2025 1055 LPL Way Fort Mill, SC 29715 (704) 733-3300 www.lpl.com Marc Andrew Zabicki Louis James Carpenetti Garrett Fish Jason Hoody Kristian Kerr Jeffrey Roach Adam Turnquist Lawrence Dean Gillum Jina Yoon Quincy Krosby Thomas Shipp Craig Brown Scott Froidl Jeffrey Alan Buchbinder 201 Washington Street, Suite 300 Boston, MA 02108 (617) 423-3644 George Smith 4707 Executive Drive San Diego, CA 92121 (858) 450-9606 These Brochure Supplements provide information about certain LPL employees or officers that supplements the LPL Financial Brochure that is attached to these Brochure Supplements. Please contact LPL Financial at the number above if you did not receive the LPL Financial Brochure or if you have any questions about the contents of these Brochure Supplements. You may also contact your LPL investment advisor representative with questions. Additional information about these LPL employees or officers is available on the SEC’s website at https://adviserinfo.sec.gov/. Note that although these LPL employees or officers included in these Brochure Supplements are responsible for investment advice provided by LPL they are not the IARs responsible for the ongoing individualized investment advice provided to a particular client. For more information about the IAR managing the account, client should refer to the Brochure Supplement for the IAR, which should have been provided by the IAR along with the LPL Financial Brochure and these Brochure Supplements at the time client opened the account. If client did not receive a Brochure Supplement for the IAR, the client should contact the IAR or LPL at lplfinancial.adv@lplfinancial.com. Marc Andrew Zabicki Educational Background and Business Experience tying a portion of the compensation to Marc Zabicki was born in 1966. He has a BS in Economics from Florida State University and he is a Chartered Financial Analyst (CFA). He is Chief Investment Officer and the Director of Research for LPL Research and has been with the firm since 2020. Prior to joining LPL, he was Chief Investment Officer at Bower Hill Capital Management. Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and the outperformance of all LPL managed portfolios. Disciplinary Information Supervision None. Other Business Activities Mr. Zabicki is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation Mr. Zabicki is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs, and he reports to Rob Pettman, Executive Vice President. The advice provided by Mr. Zabicki is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The Chief Compliance Officer (“CCO”), Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Mr. Zabicki receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 1 L P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS Louis James Carpenetti Educational Background and Business Experience is a Senior Vice President and Head of Model Portfolio Management at LPL and joined LPL in 2022. Prior to joining LPL, Mr. Fish was a Portfolio Manager at JPMorgan Asset Management. Disciplinary Information None. Other Business Activities Louis James Carpenetti was born in 1971. He has a BS in Management from Palm Beach Atlantic University, an MBA from Georgia College & State University, a CFA Charterholder and has earned the CFP® certification. He is a Senior Vice President of Trading at LPL and joined LPL in July 2021. Prior to joining LPL, Mr. Carpenetti was Managing Director for Truist for 22 years serving in a variety of management and trading capacities. Disciplinary Information Mr. Fish is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. None. Additional Compensation Other Business Activities Mr. Carpenetti is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation tying a portion of the compensation to Mr. Fish receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, the and outperformance of all LPL managed portfolios. Supervision tying a portion of the compensation to Mr. Carpenetti receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, the and outperformance of all LPL managed portfolios. Supervision Mr. Fish reports to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Fish is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Jason Hoody Educational Background and Business Experience As a Senior Vice President, Mr. Carpenetti is responsible for trade execution in LPL’s advisory programs, subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Garrett Fish Educational Background and Business Experience Jason Hoody was born in 1975. He has a BS in Political Science from Clarkson University, an MA in International Affairs from American University, an MS in Finance from Johns Hopkins University, and is a CFA Charterholder. He is a Senior Vice President in Research at LPL and joined LPL in 2015. Prior to joining LPL, he was a Vice President at BB&T and an analyst at KPMG. Garrett Fish was born in 1969. He has a BA in Japanese History from Bates College and is a CFA Charterholder. He B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 2 L P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS Additional Compensation Disciplinary Information None. Other Business Activities None. Additional Compensation tying a portion of the compensation to Mr. Kerr receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and the outperformance of all LPL managed portfolios. Supervision tying a portion of the compensation to Mr. Hoody receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, the and outperformance of all LPL managed portfolios. Supervision Mr. Kerr reports to Mr. Zabicki, the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Kerr is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Jeffrey Roach Educational Background and Business Experience in 1973. He has a BS Mr. Hoody reports to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Hoody is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Kristian Kerr Educational Background and Business Experience in 1977. He has a BBA Jeffrey Roach was born in Mathematics from Bob Jones University and a MA and PhD in Economics from Clemson University. He is Chief Economist at LPL and joined LPL in 2022. Prior to joining LPL, Dr. Roach was Senior US Economist for Visa Inc, Managing Director, Economist at MacroView Partners and Chief Economist at Horizon Investments. Disciplinary Information None. Other Business Activities Kristian Kerr was born in International Business from Schiller International University in Madrid, Spain. He is a Senior Vice President and the Head of Macro Strategy at LPL and joined LPL in 2023. Prior to joining LPL, Mr. Kerr worked at Citi Private Bank as the Western Region Head of Foreign Exchange & Macro. Disciplinary Information None. Dr. Roach is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Other Business Activities Additional Compensation Mr. Kerr does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Dr. Roach receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 3 L P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS capping the amount of compensation paid regardless of the return, and tying a portion of the compensation to the outperformance of all LPL managed portfolios. Supervision tying a portion of the compensation to Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and the outperformance of all LPL managed portfolios. Supervision Mr. Turnquist reports up to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Turnquist is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Lawrence Dean Gillum Educational Background and Business Experience Dr. Roach reports to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Dr. Roach is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Adam Turnquist Educational Background and Business Experience Lawrence Gillum was born in 1974. He has a BS from University of Florida and a Master in Business Administration from the University of North Carolina, Keenan Flagler Business School. He is a Vice President of Research at LPL and joined LPL in 2021. Prior to joining LPL, Mr. Gillum served as a Director at Raymond James where he oversaw fixed income research within the firm’s discretionary model platform. Disciplinary Information Adam Turnquist was born in 1984. He has a BS from the University of Minnesota-Duluth and an MBA from the University of St. Thomas. He is Chief Technical Strategist and joined LPL in 2022. Prior to joining LPL, Mr. Turnquist worked as a Vice President, Technical Research Analyst at Piper Sandler. None. Disciplinary Information Other Business Activities None. Other Business Activities Mr. Gillum is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation is a registered representative of LPL. Mr. Turnquist However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation Mr. Gillum receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, Mr. Turnquist receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short- term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 4 L P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS tying a portion of the compensation to the Supervision and outperformance of all LPL managed portfolios. Supervision Ms. Yoon reports up to Mr. Zabicki, the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Ms. Yoon is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Quincy Krosby Educational Background and Business Experience Mr. Gillum reports up to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Gillum is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Jina Yoon Educational Background and Business Experience Quincy Krosby was born in 1948. She has an MPhil and PhD from The London School of Economics. She is Chief Global Strategist at LPL and joined LPL in 2022. Prior to joining LPL, Ms. Krosby worked at Prudential Financial as Chief Market Strategist. is Chief Alternate Disciplinary Information None. Other Business Activities Jina Yoon was born in 1983. She has a BS and MEng from Investment Cornell University. She Strategist at LPL and joined LPL in 2023. Prior to joining LPL, Ms. Yoon was the Head of Portfolio Management & Senior Portfolio Manager at Nomura Private Capital. Prior to Nomura, she served both Institutional and Private Wealth Clients as the Head of Tactical Strategies at Credit Suisse. Disciplinary Information None. Ms. Krosby is a registered representative of LPL. However, she does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Other Business Activities Additional Compensation Ms. Krosby receives a regular salary. Supervision Ms. Yoon does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation Ms. Krosby reports to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. This is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Ms. Yoon receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short- term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and tying a portion of the compensation to the outperformance of all LPL managed portfolios. B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 5 L P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS Thomas Shipp Educational Background and Business Experience University and a MAIS in Computational Social Science from George Mason University. He is a Vice President and Head of Quant Strategy at LPL and joined LPL in 2021. Prior to joining LPL, Mr. Brown was a Senior Associate in Investment Analytics and Data at Dimensional Fund Advisors. Disciplinary Information None. Thomas Shipp was born in 1984. He has a BS in Business Administration from Fordham University and is a CFA Charterholder. He is a Vice President and Head of Equity Research at LPL and joined LPL in 2017. Prior to joining LPL, Mr. Shipp was an Associate in the Equity Research Department at BMO Capital Markets. Other Business Activities Disciplinary Information None. Mr. Brown does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Other Business Activities Additional Compensation Mr. Shipp is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation Mr. Brown receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short- term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and tying a portion of the compensation to the outperformance of all LPL managed portfolios. Supervision Mr. Shipp receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short- term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and tying a portion of the compensation to the outperformance of all LPL managed portfolios. Supervision Mr. Brown reports to Mr. Zabicki, the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Brown is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Scott Froidl Educational Background and Business Experience Mr. Shipp reports to Mr. Zabicki, the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Shipp is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Craig Brown Educational Background and Business Experience Scott Froidl was born in 1971. He has a BS from Lindenwood University. He is an Assistant Vice President Senior Investment Analyst at LPL and joined LPL in 2021. Prior to joining LPL, Mr. Froidl was a Senior Investment Analyst at Wells Fargo from 2018 until 2021 and Senior Investment Analyst at Stifel in 2018 while starting with the firm in 2001. Craig Brown was born in 1988 He has a dual BS in Economics and Information Analysis from James Madison B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 6 L P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS Other Business Activities Disciplinary Information None. Other Business Activities Mr. Buchbinder is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation Mr. Froidl is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation tying a portion of the compensation to Mr. Buchbinder receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, the and outperformance of all LPL managed portfolios. Supervision Mr. Froidl receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short- term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and tying a portion of the compensation to the outperformance of all LPL managed portfolios. Supervision Mr. Buchbinder reports up to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Buchbinder is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. George Smith Mr. Froidl reports to Mr. Zabicki, the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Froidl is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Educational Background and Business Experience Jeffrey Alan Buchbinder in 1983. He has a BS Educational Background and Business Experience in George Smith was born Mathematics from the University of Bristol in the United Kingdom (UK). He is Portfolio Strategist at LPL and joined LPL in 2013. Prior to joining LPL, Mr. Smith worked in London, UK for Legal and General Investment Management (LGIM) and Goldman Sachs Asset Management (GSAM). Disciplinary Information None. Jeffrey Alan Buchbinder was born in 1971. He has a BA in Economics from Northwestern University and an MBA from Duke University. He is Chief Equity Strategist and Portfolio Manager for LPL Financial Research and has been with the firm since 2003. Prior to joining LPL, he served as an Equity Research Associate at Sanford C. Bernstein. Prior to Bernstein, he was an Equity Research Associate at Deutsche Bank. Other Business Activities Disciplinary Information None. Mr. Smith is a registered representative of LPL. However, he does not engage in the sale of securities or receive B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 7 L P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS commissions or other compensation based on the sale of securities or other investment products. Additional Compensation Mr. Smith receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short- term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and tying a portion of the compensation to the outperformance of all LPL managed portfolios. Supervision Mr. Smith reports up to Mr. Zabicki, the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Smith is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877- 7210. B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 8 L P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C 

OPTIMUM MARKET PORTFOLIOS (OMP) PROGRAM BROCHURE LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 October 22, 2025 the contents of this brochure, please contact your LPL This program brochure provides information about the qualifications and business practices of LPL Financial (“LPL”). If you have any questions about financial advisor or LPL at lplfinancial.adv@lplfinancial.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about LPL also is available on the SEC’s website at https://adviserinfo.sec.gov/. ITEM 1 COVER PAGE ITEM 2 MATERIAL CHANGES The following is a summary of certain changes made to this Brochure from the time of the most recent annual update dated March 28, 2024. Item 6 was updated to provide that effective November 24, 2025, LPL will be responsible for voting proxies solicited by, or with respect to, the issuers of any securities held in the account, except to the extent otherwise prohibited by law and unless clients opt to retain voting responsibility. Additional risk disclosures were added in Item 6 related to third-party service providers’ or any counterparties’ potential use of artificial intelligence and machine learning. Item 9 was updated to provide information regarding disciplinary events involving (i) a settlement with the SEC that included a $50 million fine for failing to maintain required records of certain business-related communications; and (ii) a settlement with the SEC that included an $18 million fine for LPL not following its anti-money laundering policies for its customer identification program and ongoing customer due diligence obligations. Item 9 was also updated to reflect the following setup fee charges payable to LPL by model managers or product sponsors, if applicable to the program: (i) a yearly $5,000 per strategy fee for annual due diligence reviews and maintenance; (ii) the one-time sponsor-level mutual fund setup fee was reduced from $40,000 to $15,000, with the per-fund setup fee increasing from $5,000 to $7,500; (iii) up to $15,000 as a sponsor level due diligence fee for exchange traded products; and (iv) a $5,000 per-trust fee for each unit investment trust. In addition, Item 9 was updated to disclose conflicts related to LPL’s decision to make certain product sponsors available on the applicable platforms when certain sponsors reimburse LPL for technology development related costs associated with the launch or maintenance of a platform, tool, or service. Item 9 was updated to provide that LPL financial advisors may assist you by providing rollover investment advice if you are contemplating whether to roll your retirement assets out of an employer-sponsored plan, such as a 401(k), to an IRA. Item 9 was also updated to disclose risks related to LPL’s ability to block or review client orders before they are directed to an exchange or market maker for execution. This may result in a delay in execution, which could cause (i) a difference between execution price and the displayed quote at the time the order was entered; and (ii) a limit order becoming ineligible for execution. Item 9 was also updated to include additional information about LPL’s Dividend Reinvestment Program (DRP). ITEM 3 TABLE OF CONTENTS ITEM 1 COVER PAGE ................................................................................................................................................. 1 ITEM 2 MATERIAL CHANGES ................................................................................................................................... 1 ITEM 3 TABLE OF CONTENTS .................................................................................................................................. 1 ITEM 4 SERVICES, FEES AND COMPENSATION ..................................................................................................... 2 ITEM 5 ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ............................................................................... 5 ITEM 6 PORTFOLIO MANAGER SELECTION AND EVALUATION........................................................................... 5 ITEM 7 CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ............................................................. 8 ITEM 8 CLIENT CONTACT WITH PORTFOLIO MANAGERS .................................................................................... 8 A 1 2 – 1 0 2 5 P a g e 1 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE ITEM 9 ADDITIONAL INFORMATION ....................................................................................................................... 8 ITEM 4 SERVICES, FEES AND COMPENSATION Services LPL offers various types of advisory services and programs, including wrap fee programs, mutual fund asset allocation programs, advisory programs offered by third party investment advisor firms, financial planning services, an advisor-enhanced digital advice program, and retirement plan consulting services. This Brochure provides a description of the advisory services offered under LPL’s Optimum Market Portfolios (“OMP”) program. For more information about LPL’s advisory services and programs other than OMP, please contact your Investment Adviser Representative (“IAR”) for a copy of a similar brochure that describes such service or program or go to https://adviserinfo.sec.gov. LPL conducts its advisory business under the name “LPL Financial LLC,” as indicated in Form ADV and its communications and investment advisory agreements with clients. Although LPL and certain LPL IARs use separate marketing names or “doing- business-as” (DBA) designations, LPL does not conduct any advisory business primarily through any of those entities. IARs are required by applicable rules and policies to obtain licenses and complete certain training in order to recommend certain investment products and services. You should be aware that your IAR, depending on the licenses or training obtained, may or may not be able to recommend certain investments, models, programs, or services. In addition, your IAR may be located at a financial institution that does not offer certain products, investments, models, programs, or services. Please ask your IAR whether any limitations apply. LPL is also a broker-dealer registered with the Financial Industry Regulatory Authority (“FINRA”), and an IAR also may be registered with LPL as a broker-dealer registered representative. Therefore, an IAR may be able to offer a client both investment advisory and brokerage services. Before engaging with an IAR, clients should take time to consider the differences between an advisory relationship and a brokerage relationship to determine which type of service best serves the client’s investment needs and goals. All recommendations regarding advisory accounts will be in an advisory capacity, and any recommendations regarding any brokerage account a client opens with LPL will be in a brokerage capacity, unless a client is expressly told otherwise. Clients should speak to the IAR to understand the different types of services available through LPL. Not all LPL IARs have access to all products and services. The OMP program is a professionally managed mutual fund asset allocation program in which LPL and its IARs provide ongoing investment advice and management. The IAR obtains the necessary financial data from the client, assists the client in determining the suitability of the program and assists the client in setting an appropriate investment objective. The IAR selects a model portfolio of mutual funds (“Portfolio”) designed by LPL’s Research Department consistent with the client’s stated investment objective. The Portfolios are made up of mutual funds in the Optimum Funds mutual fund family. A Portfolio may include up to six Optimum Funds. The OMP program also permits clients to select a third party investment advisor firm typically associated with an LPL registered representative, in lieu of an IAR, to provide the advisory services described in this brochure. LPL has discretion to buy and sell securities in the account and will invest the account based on the Portfolio selected. LPL rebalances accounts based on the allocations in the Portfolio as described below. LPL reviews the account for rebalancing on the frequency selected by the client at account opening or as altered by the IAR or the client from time to time. The choices for frequency of rebalancing are quarterly (four times per year), semi-annually (two times per year) or annually (once per year). Accounts are reviewed on the frequency selected based on the anniversary date of account opening, to determine if rebalancing is necessary. An additional rebalance may be requested outside of the scheduled frequency once every 12 months. At each rebalancing review date, accounts are rebalanced if the Account has available cash for investment and at least one of the account positions is outside a range determined by LPL, subject to a minimum transaction amount established by LPL in its discretion. In addition, LPL may review the account for rebalancing in the event that LPL Research changes the model portfolio. LPL may accommodate requests by client or IAR for all or a portion of the assets in the account to remain allocated to cash for a period of time. Such customized Portfolio requests, liquidation requests in connection with withdrawals, and changes to the A 1 2 – 1 0 2 5 P a g e 2 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE Portfolio or investment objective selected may take up to 5 business days to process, and, in certain circumstances, may take longer. LPL invests deposits in an account according to the Portfolio, but such deposits (or a portion thereof) may be liquidated and the proceeds may remain in cash until certain conditions are met related to trade size and positive deviation from the target allocation. Although OMP accounts are not considered tax efficient or tax managed, LPL may delay placing transactions on non- retirement accounts by one day for any rebalancing scheduled to occur on the first one year anniversary date of the account opening in an attempt to limit the tax treatment of realized short-term gains for any position being sold. LPL may also apply discretion to deviate from the model portfolios in accounts, in which it is not possible or impractical to be invested in all of a model’s holdings, for example in smaller accounts. In connection with the program, LPL also acts as custodian to accounts, provides brokerage services as the broker-dealer on transactions, and performs administrative services, such as performance reporting to clients. IARs may, in their sole discretion and as agreed from time to time with clients, provide financial planning or financial consulting services to clients in connection with the program at no additional cost. IARs may also require clients to enter into a separate agreement with an agreed upon fee for financial planning or financial consulting services. The scope and duration of financial planning and consulting services varies, will generally be agreed upon at the time the IAR provides the services, and may include comprehensive financial planning or consulting on a particular issue such as retirement planning, education planning, estate planning, cash flow/budget planning, risk management planning, personal wealth planning, tax planning, business planning, investment planning/asset allocation, or other planning as needed. Financial planning and consulting may or may not include a written, customized financial plan. Fee Schedule Clients in the OMP program pay LPL an annualized fee (“Account Fee”) for the asset management services of LPL and IAR, as well as the administrative and custodial services of LPL. The Account Fee is shared with the IAR. The Account Fee is negotiable between the client and the IAR and is based on the value of assets in the account, including cash holdings, and payable quarterly in advance. The maximum Account Fee is 2.50%. Upon request, the Account Fee also may be structured on a tiered basis, with a reduced percentage rate based on reaching certain thresholds. LPL reserves the right to increase the upper limit of the Advisory Fee and/or Manager Fee range(s) upon 30 days’ prior notice to clients. LPL and IARs do not charge performance-based fees to accounts in the OMP program. LPL may retain a portion of the Account Fee for its administrative and custodial services. LPL shares up to 100% (typically between 90% to 100%) of the remaining portion of the Account Fee with the IAR based on the agreement between LPL and the IAR. A portion of the fee to the IAR may be paid by the IAR to his or her LPL branch manager or another LPL representative for supervision or administrative support. There is a conflict of interest when a branch manager receives a portion of the Account Fee for supervision because the fee affects his or her ability to provide objective supervision of the IAR. How the Account Fee is Charged LPL deducts the Account Fee and other fees and charges associated with an OMP account from the account. LPL calculates and deducts the Account Fee in the method described in the Account Agreement, unless other arrangements are made in writing. If a client wishes to be billed for the Account Fee, rather than a deduction directly from the account, the client needs to make a request to LPL through the IAR. Payment in Advance and Refund of Pre-Paid Fees LPL deducts the Account Fee quarterly in advance. If the Account Agreement is terminated before the end of the quarterly period, LPL will pay the client a prorated refund of any pre-paid quarterly Account Fee based on the number of days remaining in the quarter after the termination date. However, if the account is closed within the first six months by the client or as a result of withdrawals that bring the account value below the required minimum, LPL reserves the right to retain the pre-paid quarterly Account Fee for the current quarter in order to cover the administrative costs of establishing the account (for example, the costs related to transferring positions in and out of the account, data entry in opening the account, reconciliation of positions in order to issue performance information, and re-registration of positions). A 1 2 – 1 0 2 5 P a g e 3 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE Other Types of Direct Fees and Expenses of LPL In addition to the Account Fee, LPL assesses a transaction charge of $5 on each purchase and sale transaction. The transaction charge is identified under the service charge column on trade confirmations and represents a payment for expenses associated with trade execution and processing, including for preparing, printing and/or delivering confirmations. Transaction charges are waived if eligible contribution within the previous 365 days, including transfers, wires, checks, ACH or journal, are made to the account. Transaction charges present conflicts of interest. For example, where transaction charges apply, the more transactions Client enters into, the more compensation LPL receives. The transaction charge may be higher or lower than commissions otherwise payable in the absence of the Account Fee. When an investment change is made to the account (e.g., for transactions resulting from contributions, rebalancing, model changes, and withdrawals), the transaction charge can represent a meaningful cost to Client, in particular, at smaller account sizes. LPL does not share any portion of the transaction charge with the IAR. Clients also pay LPL other additional miscellaneous administrative or custodial-related fees and charges that apply to an OMP account. LPL notifies clients of these charges at account opening and makes available a current list of these charges on its website at lpl.com/disclosures.html. These fees include retirement account fees and termination fees, including, for example, a fee for loans processed for qualified retirement plan and 403(b)(7) plan accounts and an account termination fee for processing a full account transfer to another financial institution. These transaction charges and other direct fees are not directly based on the costs of the transaction or service by LPL, may include a profit to LPL, and certain of the fees may be lowered or waived for certain clients. Fees Charged by Third Parties, Including the Optimum Funds There are other fees and charges that are imposed by third parties other than LPL that apply to investments in OMP accounts. In OMP, assets are invested in mutual funds and, therefore, there are two layers of advisory fees and expenses for those assets. As a shareholder of a Fund, Client will pay an advisory fee to the investment advisor of the Optimum Funds and other expenses charged by the Fund. Client will also pay LPL and IAR the Account Fee with respect to assets invested in the Funds. The Optimum Funds or funds with similar investment objectives may be purchased directly outside of the Program. Therefore, clients could generally avoid the second layer of fees by not using the advisory services of LPL and IAR and by making their own decisions regarding mutual fund investing. The amount of the advisory fees and other expenses of the Optimum Funds is set out in the prospectus and financial statements of the Optimum Funds, which are available upon request from IAR or the Optimum Funds directly. Clients should understand that in many cases the mutual funds and mutual fund share classes offered through the Program charge higher fees and expenses than those that are not offered through the Program, and such other mutual funds and share classes may be equally or more appropriate for a client’s account. As discussed below, Client should understand that a portion of the fees and expenses Client pays as a shareholder of the Optimum Funds is used by the sponsor of the Funds to pay LPL for services LPL provides with respect to the funds. See Item 9, “Participation or Interest in Client Transactions,” for more information on the payments received by LPL with respect to the Optimum Funds. Other financial services firms, including those LPL makes available through its third-party asset management programs, may offer the same mutual funds that are offered through the Program but at lower overall costs to investors than the costs that clients incur by investing through the Program. If client transfers into an OMP account a previously purchased mutual fund, and there is an applicable contingent deferred sales charge on the fund, client will pay that charge when the mutual fund is sold. If the account is invested in a mutual fund that charges a fee if a redemption is made within a specific time period after the investment, client will be charged a redemption fee. Depending on the share class and fee structure of the previously purchased mutual fund, LPL can receive fees such as 12b-1 fees from the previously purchased mutual fund until the position is liquidated and subsequently invested according to the OMP model. Any 12b-1 fees paid to LPL by mutual funds transferred into an account will be credited to the client’s account. If a mutual fund has a frequent trading policy, the policy can limit a client’s transactions in shares of the fund (e.g., for rebalancing, liquidations, deposits or tax harvesting). Decisions regarding the sale of mutual funds in an account may be made by LPL without regard to whether a client will be assessed a redemption fee. Clients can find more information regarding the fees and A 1 2 – 1 0 2 5 P a g e 4 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE expenses of a mutual fund or ETF in the fund’s prospectus, which is available upon request from the IAR or directly from the fund. When transferring securities into an OMP account, client should be aware that certain securities are not be eligible for the account. In such case, the securities may be rejected, sold after the transfer, or moved to a brokerage account. Note that when an ineligible security is transferred into an account and subsequently sold or moved to a brokerage account, the advisory fee will be charged on such asset for the period of time the security was held in the account. Client should be aware that securities transferred into an account may have been subject to a commission or sales load when the security was originally purchased. After transfer into an OMP account, client should understand that an advisory fee will be charged based on the total assets in the account, including the transferred security. When transferring securities into an account, client should consider and speak to IAR about whether: (cid:120) (cid:120) (cid:120) a commission was previously paid on the security; client wishes for the security to be managed as part of the account and be subject to an advisory fee; or client wishes to hold the security in a brokerage account that is not managed and not subject to an advisory fee. Important Things to Consider About Fees on an OMP Account type and size of the account (cid:120) The Account Fee is a single fee for investment advisory services and other administrative and custodial services. Clients do not pay a commission to LPL but do pay a transaction charge (unless waived) as described above. The Account Fee may cost the client more than purchasing the program services separately, for example, paying an advisory fee plus commissions to a broker-dealer for each transaction in the account. Factors that bear upon the cost of the account in relation to the cost of the same services purchased separately include the: (cid:120) (cid:120) historical and/or expected size or number of trades for the account, and (cid:120) number and range of supplementary advisory and client-related services provided to the client. (cid:120) The Account Fee may be higher than the fees charged by other investment advisors for similar services. This is the case in particular if the Account Fee is at or near the maximum Account Fee set out above. The IAR is responsible for determining the Account Fee to charge each client based on factors such as total amount of assets involved in the relationship and the complexity, number and range of supplementary advisory and client-related services to be provided to the account. Clients should consider the level and complexity of the advisory services to be provided when negotiating the Account Fee with IAR. (cid:120) The investment products available to be purchased in the program can be purchased by clients outside of an OMP account, through broker-dealers or other investment firms not affiliated LPL. (cid:120) Clients should consider the impact of fees and expenses on their investment portfolio, as described in the informational brochure titled “How Fees and Expenses Affect Your Portfolio” on lpl.com/disclosures.html under “Investor Regulatory & Educational Resources.” ITEM 5 ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS LPL generally requires a minimum account value of $1,000, but eligible contribution within the previous 365 days, including transfers, wires, checks, ACH or journal, are required for account sizes below $10,000. In certain instances, LPL will permit a lower minimum account size. An account will not be invested according to the Portfolio until the minimum has been reached. The program is available for individuals, Individual Retirement Accounts (“IRAs”), banks, thrift institutions, credit unions, pension and profit sharing plans, including plans subject to Employee Retirement Income Security Act of 1974 (“ERISA”), trusts, estates, charitable organizations, state and municipal government entities, corporations and other business entities. ITEM 6 PORTFOLIO MANAGER SELECTION AND EVALUATION In OMP, LPL does not select, review or recommend the services of other investment advisor or portfolio management firms. LPL and its IARs are responsible for the investment advice and management offered to clients, and the client selects the IAR who services the account. Each IAR is generally required to possess a FINRA Series 65 or 66 license (to the extent required). For more information about the IAR managing the account, client should refer to the Brochure Supplement for the IAR, available from the IAR. A 1 2 – 1 0 2 5 P a g e 5 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE In OMP, clients invest in Portfolios designed by LPL’s Research Department. LPL Research designs different types of Portfolios for OMP to meet the varying needs of clients. The IAR selects the Portfolio and provides advice based on the client’s individual needs. LPL receives a portion of the Account Fee for the Portfolio design services of LPL Research. LPL and its IARs do not accept performance-based fees under OMP. LPL’s Research Department uses the following investment strategies in designing Portfolios. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. Investing in securities involves the risk of loss that clients should be prepared to bear. Each of these investment strategies seek to generate capital appreciation while assuming a reasonable amount of risk. (cid:120) Standard. These Portfolios invest in up to six Optimum Funds across the following asset classes: large growth, large value, small/mid growth, small/mid value, international, and fixed income. (cid:120) U.S. These Portfolios invest in up to five Optimum Funds across the following asset classes: large growth, large value, small/mid growth, small/mid value, and fixed income. These Portfolios do not invest in international. (cid:120) Growth Tilt. These Portfolios invest in up to six Optimum Funds across the following asset classes: large growth, large value, small/mid growth, small/mid value, international, and fixed income. These Portfolios are over-weighted to growth relative to the standard models. (cid:120) Value Tilt. These Portfolios invest in up to six Optimum Funds across the following asset classes: large growth, large value, small/mid growth, small/mid value, international, and fixed income. These Portfolios are over-weighted to value relative to the standard models. For Standard and U.S. Portfolios described above, LPL Research makes available a strategic or tactical version for each Portfolio. The strategic Portfolios are intended to take advantage of market opportunities that will occur or persist over a three-to-five- year time frame. The tactically managed Portfolios are intended to take advantage of short-, medium-, or long-term opportunities. In addition, for the Standard Portfolios there are two different versions of the tactically-managed portfolios: Traditional Standard and Spectrum Standard. The asset allocation of the Traditional Standard Portfolios is set primarily leveraging the LPL Research macroeconomic views. The asset allocation of the Spectrum Standard Portfolios is set primarily leveraging the LPL Research diligence views. Types of Investments and Risks Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some risks associated with investing. (cid:120) Market Risk. This is the risk that the value of securities owned by an investor may go up or down, sometimes rapidly or (cid:120) unpredictably, due to factors affecting securities markets generally or particular industries. Interest Rate Risk. This is the risk that fixed income securities will decline in value because of an increase in interest rates; a bond or a fixed income fund with a longer duration will be more sensitive to changes in interest rates than a bond or bond fund with a shorter duration. (cid:120) Economic Conditions Risk. This is the risk that economic, political or financial developments will, from time to time, result in periods of volatility or other adverse effects that could negatively impact your account. (cid:120) Credit Risk. This is the risk that an investor could lose money if the issuer or guarantor of a fixed income security is unable (cid:120) or unwilling to meet its financial obligations. Investment Company Risk. To the extent a client account invests in ETFs or other investment companies, its performance will be affected by the performance of those other investment companies. Investments in ETFs and other investment companies are subject to the risks of the investment companies’ investments, as well as to the investment companies’ expenses. If a client account invests in other investment companies, the client account may receive distributions of taxable gains from portfolio transactions by that investment company and may recognize taxable gains from transactions in shares of that investment company, which would be taxable when distributed. (cid:120) Pledging Assets. LPL has partnered with certain banks to help facilitate clients’ access to collateralized non-purpose lines of credit; however, clients are not required to use the banks in LPL’s program, and can work directly with other banks (“non- A 1 2 – 1 0 2 5 P a g e 6 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE partner banks”) to negotiate loan terms or obtain other financing arrangements. Clients who choose to use non-partner banks should notify their IARs of the amount of the line of credit. In these collateralized lending arrangements, clients borrow from the bank and pay interest to the bank. In some cases, an IAR may recommend that a client seeking to access funds (for purposes other than purchasing securities) hold his securities investments and instead utilize a non-purpose line of credit collateralized by the assets in his advisory account. Unless an IAR specifically recommends that a client hold his securities investments and instead utilize a collateralized line of credit to access funds, the decision regarding whether to arrange for a collateralized loan and the decision to draw down on such a loan are not covered by a client’s advisory relationship with LPL or his IAR. While an IAR may assist the client with facilitating a line of credit, clients are responsible for independently evaluating the terms of the loan and deciding whether the loan meets their needs. Clients also should be aware that pledging assets in an account to secure a loan involves additional risks. The bank holding the loan has the authority to liquidate all or part of the securities at any time without your prior notice in order to maintain required maintenance levels, or to call the loan at any time. As a practical matter, this may cause you to sell assets and realize losses in a declining market. Moreover, an IAR’s ability to make investment decisions or recommendations for the account may be restricted by collateral requirements imposed by the bank. These restrictions or a forced liquidation may interfere with your long term investment goals and/or result in adverse tax consequences. Further, you should note that the returns on accounts or on pledged assets may not cover the cost of loan interest and advisory fees. Clients should be aware that LPL’s collateralized loan program is one way, among many, for clients to raise necessary cash. Before pledging assets in an account, clients should carefully review the loan agreement, loan application and any forms required by the bank and any other forms and disclosures provided by LPL. For a list of the banks currently participating in LPL’s collateralized lending program, please visit lpl.com/disclosures.html, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Third Party Compensation and Related Conflicts of Interest.” (cid:120) Cybersecurity Risk. Failures or breaches of the electronic systems of LPL, its service providers, securities market participants or the issuers of securities can cause significant losses for investors. Unintentional cyber events, such as the inadvertent release of confidential information, could also adversely impact investor account. Any cyber event could cause result in the loss or theft of investor data or cause investors financial loss and expense. (cid:120) Use of Artificial Intelligence and Machine Learning. Recent technological advances in artificial intelligence, generative artificial intelligence, and machine learning technology (collectively, “Machine Learning Technology”) may pose risks to LPL and its IARs. LPL and its IARs could be further exposed to the risks of Machine Learning Technology if third-party service providers or any counterparties, whether or not known to LPL or its IARs, also use Machine Learning Technology in their business activities. LPL and its IARs will not be in a position to control the operations of third-party service providers or counterparties, the manner in which third-party products are developed or maintained or the manner in which third-party services are provided. Machine Learning Technology is generally highly reliant on the collection and analysis of large amounts of data, and it is not possible or practicable to incorporate all relevant data into the model that Machine Learning Technology utilizes to operate. Certain data in such models will inevitably contain a degree of inaccuracy and error, potentially materially so, and could otherwise be inadequate or flawed, which would be likely to degrade the effectiveness of Machine Learning Technology. To the extent that LPL or its IARs are exposed to the risks of Machine Learning Technology, any such inaccuracies or errors could have adverse impacts on LPL or its IARs, as applicable. Machine Learning Technology and its applications, including in the financial services sector, continue to develop rapidly, and it is impossible to predict the future risks that will from time to time arise from such developments. (cid:120) Values-Based and Environmental, Social and Governance (ESG) Investing Risk. Values-based investing or ESG investing, also known as “socially responsible investing,” “sustainable investing,” or “impact investing,” focuses on the social values or environmental, social, and governance standards or the sustainability factors of an investment. Some values-based investing strategies focus on factors relating to an individual investor’s personal or religious values, such as “biblical investing,” while other strategies focus on issues like environmental impact. Some values-based investment strategies use values-based criteria to supplement financial analysis when considering a particular issuer or security, while others affirmatively select “socially responsible” investments or screen out or exclude investments in companies that engage in certain activities. Values-based investing may limit the type and number of investments available in a strategy and cause the strategy to underperform other strategies without a values-based focus or with a focus that involves a different type of focus or A 1 2 – 1 0 2 5 P a g e 7 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE screening methodology. Values-based strategies may underperform the market as a whole. Companies and issuers selected in a values-based strategy may not or may not continue to demonstrate values-based characteristics. Different investors likely have different opinions about what types of investments are socially responsible. Voting Client Securities Unless a client instructs otherwise, effective November 24, 2025, LPL will vote proxies in accordance with its proxy voting policies and procedures then in effect, which will include engaging one or more third party proxy advisor vendors to make proxy voting recommendations and handle the administrative functions of voting proxies. For OMP, LPL’s proxy voting policies and procedures state that LPL will vote proxies in all instances in accordance with recommendations from Glass, Lewis & Co., a third-party proxy advisory services company, for any securities held in your account, except to the extent otherwise prohibited by law. For the avoidance of doubt, in the event that Glass, Lewis & Co. does not provide a recommendation, LPL will abstain from voting in that proxy campaign. Notwithstanding the foregoing, if Client is a plan subject to ERISA (as defined above), LPL shall vote client proxies in accordance with LPL’s obligations under ERISA and applicable Department of Labor Regulations. Client may expressly retain the right and obligation to vote any proxies or exercise any voluntary corporate actions relating to securities held in the Account, provided Client provides prior written notice to LPL. A copy of LPL’s proxy voting policies is available upon request to IAR. A client can obtain information about how LPL voted with respect to securities held in the client’s account by contacting IAR. If a client elects to retain the right and obligation to vote proxies and receive mutual fund shareholder reports, LPL is reimbursed by the proxy issuer or mutual fund for the delivery costs to send proxies and shareholder reports to the client. The maximum fee that can be charged for delivery is set by New York Stock Exchange (NYSE) rules. If LPL uses a vendor to perform the delivery, the vendor seeks reimbursement from the proxy issuer or mutual fund on LPL’s behalf and in certain cases remits a portion of the reimbursement to LPL. If clients have questions regarding the solicitation, they should contact the contact person that the issuer identifies in the proxy materials or IAR. In addition, LPL and IARs do not accept authority to take action with respect to legal proceedings relating to securities held in the account. ITEM 7 CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS The IAR obtains the necessary financial data from the client and assists the client in setting appropriate investment objectives for the account. The IAR obtains this information by having the client complete an Account Application which is a part of the Account Agreement. In quarterly communications, LPL asks clients to contact the IAR if there have been any changes in the client’s financial situation or investment objectives or if they wish to impose any reasonable restrictions on the management of the account or reasonably modify existing restrictions. Clients should understand that the investment objective selected for the program in the Account Application is an overall objective for the entire account and may be inconsistent with a particular holding and the account’s performance at any time. Client also should be aware that achievement of the stated investment objective is a long-term goal for the account. ITEM 8 CLIENT CONTACT WITH PORTFOLIO MANAGERS LPL does not place any restrictions on a clients’ ability to contact and consult with IARs. ITEM 9 ADDITIONAL INFORMATION Disciplinary Information LPL entered into a settlement with the SEC in which the SEC found that LPL willfully violated its obligations under Section 17(a) of the Exchange Act and Rule 17a-8 thereunder, which require broker-dealers to comply with certain anti-money laundering (“AML”) requirements. The SEC found that LPL did not follow its AML policies for its customer identification program and ongoing customer due diligence obligations by, among other things, not properly verifying new accounts; not timely closing accounts that did not pass its screening measures; and not closing or restricting certain accounts that were prohibited under LPL’s AML Policies. The SEC censured LPL and ordered LPL to cease and desist from committing or causing any violations and any future violations of such section and rule, to pay a civil monetary penalty in the amount of $18 million, and to comply with certain undertakings (2025). A 1 2 – 1 0 2 5 P a g e 8 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE LPL entered into a settlement with the SEC in which the SEC found that LPL willfully violated Section 17(a) of the Exchange Act and Rule 17a-4(b)(4) thereunder and Section 204 of the Advisers Act and Rule 204-2(a)(7) thereunder in connection with the maintenance and preservation of off-channel communications; and failed to reasonably supervise its personnel within the meaning of Section 15(b)(4)(E) of the Exchange Act and Section 203(e)(6) of the Advisers Act. LPL admitted to the facts in the settlement order and acknowledged its conduct violated the federal securities laws. The SEC ordered LPL to cease and desist from committing or causing any violations and any future violations of Section 17(a) of the Exchange Act and Rule 17a-4(b)(4) thereunder and Section 204 of the Advisers Act and Rule 204-2(a)(7) thereunder, censured it for its conduct, ordered it to pay a civil monetary penalty in the amount of $50,000,000, and ordered it to comply with certain undertakings (2024). LPL entered into a settlement with the SEC in connection with LPL’s failure to comply with its Customer Identification Program procedures. The SEC found that LPL willfully violated Section 17(a) of the Exchange Act and Rule 17a-8 thereunder and was a cause of a third party’s violations of Sections 17(a)(2) and (3) of the Securities Act and Section 206(2) of the Advisers Act. The SEC ordered LPL to cease and desist from committing or causing any further violations of these laws and regulations, censured LPL for its conduct, and ordered the payment of disgorgement and prejudgment interest totaling $141,202 (deemed satisfied based on LPL’s voluntary remedial payment of $4,118,876 to the impacted client), and the payment of a civil money penalty of $750,000 (2021). As part of a voluntary self-reporting initiative in 2019, LPL entered into a settlement with the SEC in which the SEC found that LPL willfully violated Section 206(2) and 207 of the Investment Advisers Act of 1940 (the “Advisers Act”) in connection with inadequate disclosure to clients of its and its associated persons’ conflicts of interest related to its receipt of 12b-1 fees and/or its selection of mutual fund share classes that pay such fees. The SEC ordered LPL to cease and desist from committing or causing any violations of Sections 206(2) and 207 of the Advisers Act, censured it for its conduct, and ordered the payment of disgorgement and prejudgment interest to affected investors totaling $9,333,516 (2019). LPL, as a broker-dealer, is a member of (“FINRA”) and has found to be in violation of FINRA’s rules related to its brokerage activities. In particular, LPL consented to sanctions related to the following matters: (cid:120) (cid:120) (cid:120) (cid:120) (cid:120) (cid:120) LPL’s supervisory systems and maintenance of books and records relating to brokerage direct business transactions, supervisory systems and misstatements about fees relating to brokerage product switch transactions, and supervisory systems relating to brokerage recommendations of publicly traded securities of business development companies (BDCs) to customers, resulting in a censure, a fine of $5.5 million, restitution to impacted customers, and an undertaking to certify that LPL has remediated the systems and procedures for making recommendations of BDCs (2023). LPL’s supervisory systems and procedures relating to the transmittal of customer funds by wire or check to third parties and maintenance of related books and records, resulting in a censure, a fine of $3,000,000, restitution to impacted clients, and an undertaking to identify and pay restitution to affected customers for certain other improper transfers (2023). LPL’s failure to accurately calculate its customer reserve requirement, failure to maintain a sufficient customer reserve, failure to maintain policies and procedures reasonably designed to achieve compliance with the Securities and Exchange Act and FINRA rules, and failure to maintain accurate books and records, resulting in a censure and a fine of $300,000 (2022). LPL’s self-reporting of potential issues related to certain C-share purchase suitability reviews and its supervisory systems and procedures relating to waivers of front-end sales charges for rollovers of 529 savings plan investments from one state plan to another, resulting in a censure and payment of restitution to impacted customers (2021). LPL’s supervisory systems and procedures relating to record retention, fingerprinting and screening of certain associated persons, and supervision of consolidated reports, resulting in a censure, a fine of $6,500,000 and an undertaking to review and enhance related policies, systems and procedures (2020). LPL’s supervisory systems and procedures relating to changes in the authority of custodians of accounts established under the Uniform Gifts to Minors Act and/or the Uniform Transfers to Minors Act, resulting in a censure, a fine of $300,000, and an undertaking to review and enhance its policies, systems, and procedures related to supervision of such accounts (2019). A 1 2 – 1 0 2 5 P a g e 9 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE (cid:120) (cid:120) (cid:120) (cid:120) (cid:120) The effectiveness of LPL’s anti-money laundering program, LPL’s failure to amend certain Forms U4 and U5, and LPL’s systems and supervisory procedures relating to Forms U4 and U5 reporting requirements, resulting in a censure and a fine of $2,750,000 and an undertaking to review the process used to disclose customer complaints on Forms U4 and U5 (2018). LPL’s brokerage supervisory and disclosure procedures related to the sale of certain brokered certificates of deposit in brokerage accounts, resulting in a censure and a fine of $375,000 (2018). LPL’s systems and supervisory procedures relating to the creation and distribution of certain required account notices, resulting in a censure, a fine of $900,000, and an undertaking to review affected processes (2016). LPL’s systems and supervisory procedures relating to the format in which certain electronic records were retained, resulting in a censure and a fine of $750,000 (2016). LPL’s various brokerage supervisory procedures, including those related to the sale of complex non-traditional ETFs, variable annuity (“VA”) contracts, real estate investment trusts (“REITs”) and other products in brokerage accounts, as well as LPL’s failure to monitor and report trades and deliver trade confirmations, resulting in a censure and a fine of $10,000,000, and restitution of $1,664,592 (2015). LPL, as a broker-dealer, is regulated by each of the 50 states and has been the subject of orders related to the violation of state laws and regulations in connection with its brokerage activities. In particular, LPL entered into consent orders related to the following matters: (cid:120) (cid:120) (cid:120) (cid:120) (cid:120) (cid:120) LPL’s supervision of electronic signature practices at an LPL branch office in Massachusetts, resulting in a fine of $250,000 and an undertaking to conduct an internal review of certain related policies and procedures (Massachusetts or “MA”, 2023). LPL’s supervision of an LPL broker-dealer/investment adviser agent’s sales of structured products, resulting in a censure, an offer of restitution to impacted clients, and a fine of $125,000 (Texas, 2022). LPL’s supervision of two LPL broker-dealer and/or investment adviser agents who pled guilty to charges of fraudulent practices with LPL customers, resulting in a cease and desist order, a fine of $350,000 and a $150,000 contribution for financial literacy and investor education initiatives, training and related materials (Connecticut, 2021). LPL’s supervision of an LPL representative under a heightened supervision plan, resulting in a cease and desist order; a fine of $275,000; payments of restitution, disgorgement and investigative costs; and offers of payment of surrender charges in connection with variable annuity contracts for impacted customers (New Hampshire or “NH”, 2020). LPL’s failure to timely register (or maintain the registration of) certain agents in MA and failure to amend Forms U4 and U5 for certain agents registered in MA, resulting in a censure, a fine of $1,100,000, and an undertaking to review and enhance its policies and procedures related to registering its agents in MA and filing reportable events (MA, 2019). LPL’s brokerage supervisory procedures relating to email review and annual branch office examinations, resulting in a civil penalty of $450,000 and an undertaking for third-party review of related processes (Indiana, 2018). (cid:120) The sale of unregistered, non-exempt securities in violation of state registration requirements, resulting (upon entry of the individual consent order) in payment to each participating state or jurisdiction of a civil penalty of $499,000, reimbursement of certain investigative expenses, remediation through repurchase of certain securities and payment of losses to certain affected customers, and certain additional undertakings (Settlement with up to 53 members of the North American Securities Administrators Association (NASAA), 2018). (cid:120) (cid:120) (cid:120) The sale of non-traded alternative investments in excess of prospectus standards or LPL’s internal guidelines and the maintenance of related books and records, resulting in a censure, a fine of $950,000, a $25,000 contribution to an investor education fund and remediation of losses to impacted customers (New Jersey, 2017). LPL’s supervisory practices for LPL representatives located on the premises of a credit union, resulting in a censure, a fine of $1,000,000, and an undertaking to avoid investor confusion specific to the name under which the credit union does business and review LPL’s related policies and procedures (MA, 2017). LPL’s oversight of certain VA transactions, resulting in a censure, a fine of $975,000, restitution to clients and former clients of an LPL representative, disgorgement of commissions retained by LPL in connection with such representative’s VA sales, and an undertaking to review such representative’s brokerage and advisory activities and LPL’s related policies and procedures (MA, 2017). A 1 2 – 1 0 2 5 P a g e 1 0 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE (cid:120) The sale in brokerage accounts of non-traded REITs in excess of prospectus standards, state concentration limits or LPL’s internal guidelines, resulting in an aggregate civil penalty of $1,425,000, reimbursement of certain investigative expenses and remediation of losses to impacted customers (Global settlement with certain members of NASAA, 2015). (cid:120) The sale of non-traded REITs in excess of prospectus standards, state concentration limits or LPL’s internal guidelines, resulting in an administrative fine of $250,000, reimbursement of investigative costs of $250,000, a $250,000 contribution to an investor education fund and remediation of losses to impacted customers (NH, 2015). (cid:120) The sale of leveraged and inverse leveraged ETFs (“Leveraged ETFs”), resulting in an administrative fine of $50,000 (Delaware), a penalty of $200,000 (MA), restitution to Delaware customers in an amount up to $150,000, restitution to MA customers in an amount up to $1,600,000, and an agreement to make certain changes in its supervisory system with respect to Leveraged ETFs (2015). (cid:120) Failure to implement procedures related to the use of senior-specific titles by LPL representatives as required under MA law, resulting in a censure and a fine of $250,000 (2015). to Investment Adviser Public Disclosure at https://adviserinfo.sec.gov/ or FINRA BrokerCheck For more information about those state events and other disciplinary and legal events involving LPL and its IARs, client should refer at https://brokercheck.finra.org/. Other Financial Industry Activities and Affiliations LPL is a broker-dealer registered with FINRA and the SEC. As a broker-dealer, LPL transacts business in various types of securities, including mutual funds, stocks, bonds, commodities, options, private and public partnerships, variable annuities, REITs and other investment products. LPL is registered to operate in all 50 states and has primarily an independent-contractor sales force of registered representatives and IARs dispersed throughout the United States. LPL has a dedicated team of employee IARs in its offices who service certain accounts, and also a small subset of IARs who operate their own offices or are located on the premises of certain financial institutions and are employees of LPL Employee Services, LLC, an LPL-affiliated company. IARs are registered representatives of LPL. LPL is also registered as an introducing broker with the Commodity Futures Trading Commission. In addition, LPL is qualified to sell insurance products in all 50 states. LPL Enterprise, LLC (“LPLE”), is a registered broker-dealer and related person of LPL. LPLE became a registered investment adviser in August Our affiliate, LPLE, is an investment adviser registered with the SEC and a broker-dealer registered with FINRA and the SEC. As a broker-dealer, LPLE transacts business in various types of securities, including mutual funds, stocks, bonds, commodities, options, private and public partnerships, variable annuities, REITs and other investment products. LPLE is registered to operate in all 50 states and has primarily an independent-contractor sales force of registered representatives and investment advisor representatives dispersed throughout the United States. If required for their positions with a registered broker-dealer, LPLE’s principal executive officers are securities licensed as registered representatives of LPL. In addition, LPLE is qualified to sell insurance products in all 50 states. LPL and The Private Trust Company, N.A. (“PTC”), a federally chartered non-depository bank licensed to provide trust services in all 50 states, are related persons. PTC serves as IRA custodian for program accounts set up as IRAs and receives an annual maintenance fee for this service. PTC also provides personal trustee services to clients for a variety of administrative fiduciary services, which services may relate to a program account. Because LPL and PTC are affiliated companies and share in revenues, there is a financial benefit to the companies if a client uses PTC as a custodian or for personal trustee services, or if a PTC client uses LPL as an investment advisor. PTC’s IRA custodian and trustee services and related fees are established under a separate engagement between the client and PTC. Fiduciary Trust Company of New Hampshire (“FTC”), a non-depository trust company, is a related person of LPL. FTC provides custodial and various other recordkeeping and services to IRAs and certain employer-sponsored plans maintained through non- OMP Program accounts. Because LPL and FTC are affiliated companies and share in revenues, there is a financial benefit to the companies if a client is referred to or otherwise elects to engage with FTC for services under another LPL program, and uses LPL as the investment advisor or broker-dealer. FTC’s custodial and recordkeeping services and related fees are established under a separate engagement between the client and FTC. A 1 2 – 1 0 2 5 P a g e 1 1 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE IARs are permitted to engage in certain LPL-approved business activities other than the provision of brokerage and advisory services through LPL, and in certain cases, an IAR could receive greater compensation through the outside business than through LPL. An IAR could also be an accountant, real estate agent, tax preparer, lawyer or refer customers to other service providers and receive referral fees, for example. As other examples, an IAR could provide advisory or financial planning services through an independent unaffiliated investment advisory firm, sell insurance, or provide third-party administration to retirement plans through a separate firm. If an IAR provides investment services to a retirement plan as a representative of LPL and also provides administration services to the plan through a separate firm, this typically means the IAR is compensated from the plan for the two services. If you engage with an IAR for services separate from LPL, you may wish to discuss with him or her any questions you have about the compensation he or she receives from the engagement. Additionally, LPL and/or its IARs may refer clients to unaffiliated firms other than investment product sponsors or financial institutions, for either investment or non-investment related products or services, in exchange for a referral fee or other forms of indirect compensation. These may include referrals for investment banking, lending, accounting, tax preparation, financial technology tools, or such other products, services or consultations that may be requested by and/or benefit a client. As applicable, clients will receive additional disclosures identifying these particular arrangements and any related compensation at the time of the referral. LPL has an affiliated insurance agency, LPL Insurance Associates, Inc. (“LPLIA”) through which IARs may sell insurance products. LPL receives compensation from issuers of life insurance (universal, variable universal, whole life, and term) and other insurance contracts that are made available by IARs, such as long term care insurance and disability insurance. The compensation includes commissions and trails, and may include payments for administrative services that LPL provides and/or payments made in connection with LPL’s marketing and sales-force education and training efforts, including LPL’s annual national sales and education conference and other conferences. IARs receive a percentage of the commissions or trailing commissions paid to LPL or LPLIA. IARs may also sell insurance through an independent unaffiliated insurance agency. An IAR may earn compensation (including trailing compensation), benefits and non-cash compensation through the third party insurance agency and may have an incentive to recommend you purchase or sell insurance products with the independent agency. Code of Ethics and Personal Trading LPL has adopted a code of ethics that includes guidelines regarding personal securities transactions of its employees and IARs. The code of ethics permits LPL employees and IARs to invest for their own personal accounts in the same securities that LPL and IARs purchase for clients in program accounts. This presents a conflict of interest because trading by an employee or IAR in a personal securities account in the same security on or about the same time as trading by a client can disadvantage the client. LPL requires in its code of ethics that LPL employees and IARs report certain personal securities transactions and holdings to LPL. LPL generally has procedures to review personal trading accounts for front-running. However, since LPL’s Research Department has sole control over trading decisions (including timing of implementation thereof) for the Model Portfolios in the Program, the potential for front-running by most employees and IARs is limited, and no such review is conducted other than for employees in LPL’s Research Department. In addition, employees in LPL’s Research Department are required to obtain pre- clearance prior to purchasing certain securities for a personal account. Employees and IARs are also required to obtain pre- approval for investments in private placements and initial public offerings. A copy of the code of ethics is available to clients or prospective clients upon request and is available at lpl.com/disclosures.html. Participation or Interest in Client Transactions A purchase of mutual fund shares may be processed through LPL’s proprietary account resulting in such purchases being characterized as principal transactions for certain reporting purposes. In such case, the shares will be purchased at the fund’s net asset value, and no additional charges will be applied to such transactions as a result of LPL’s use of a proprietary account. LPL does not otherwise engage in principal transactions with its clients in the program. LPL’s parent company, LPL Financial Holdings Inc., is a publicly traded company. LPL Financial Holdings Inc. stock may not be purchased directly in OMP accounts. However, an OMP account may include a mutual fund that holds LPL Financial Holdings Inc. stock as an underlying investment. A 1 2 – 1 0 2 5 P a g e 1 2 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE LPL provides investment consulting services to the investment advisor of the Optimum Funds. These services include assisting the investment advisor in determining whether to engage, maintain or terminate sub-advisors for the Optimum Funds. As compensation for these services, LPL receives an investment consulting fee of up to 0.22% of assets from the investment advisor to the Optimum Funds. In addition, a senior executive officer of LPL serves as a Trustee of the Optimum Funds. Certain of the Optimum Funds are subject to voluntary expense caps that may result in the adviser to the Optimum Funds waiving fees or reimbursing expenses that exceed those caps. The adviser to the Optimum Funds bears the cost of any reimbursements or waivers. LPL also performs recordkeeping, administrative and shareholder services on behalf of the Optimum Funds and receives compensation for the services based on the amount of Program assets that are invested in the funds (up to 0.15% annually). These services include establishing and maintaining accounts with the Optimum Funds, facilitating settlement of funds, responding to customer inquiries and requests, and maintaining sub-account records reflecting the issuance, exchange or redemption of shares by each program account. The receipt of this recordkeeping and investment consulting compensation by LPL is an important revenue stream and presents a conflict of interest, because LPL has a financial benefit the more assets that are invested in the Optimum Funds. The investment consulting and recordkeeping compensation is retained by LPL and is not shared with its IARs. Although LPL does not share investment consulting or recordkeeping compensation with IARs, such fees and payments will increase LPL’s profits and indirectly benefit IARs, for example by increasing the value of equity awards from LPL’s parent company to IARs or by being used by LPL to support marketing or training costs. In addition, LPL charges a setup fee to product sponsors when adding new investment products or share classes of an investment product to LPL’s investment platforms. In the case of exchange traded products, LPL receives up to $15,000 as a sponsor level due diligence fee, up to $7,500 per fund and up to an additional $15,000 per product for complex ETPs and ETPs. In the case of mutual funds, LPL receives a one-time set up fee of up to $15,000 as a sponsor level due diligence fee and a setup fee of $7,500 per fund. In the case of UITs, LPL charges up to $5,000 per trust. LPL does not share this compensation with its IARs. LPL offers product sponsors of mutual funds, closed funds, interval funds, ETFs, alternative investments, advisory strategies, annuities and life insurance contracts the opportunity to purchase analytical data, business intelligence and ad hoc reporting. This information helps product sponsors in their sales, distribution and product development efforts with respect to customers and clients and creates similar conflicts to those discussed above. LPL receives up to $600,000 annually from each product sponsor in third party compensation for this information. Cash Sweep Service Options LPL automatically transfers cash balances (including otherwise uninvested cash amounts received from the customer, securities transactions, dividend and interest payments, and other account-related activities) in a customer’s eligible accounts through the account’s designated sweep service option, where applicable. The type of sweep service options available (and how cash is held) depends on the customer’s account type. LPL offers Federal Deposit Insurance Corporation (“FDIC”)-insured bank sweep services for most customer accounts. Accounts may be eligible for the LPL Insured Cash Account (“ICA”) Program, the LPL Deposit Cash Account (“DCA”) Program, the Single Bank Insured Cash Account (“SBICA”) sweep program, or the money market mutual fund sweep, each described below. Not all sweep service options are available to all types of customer accounts. Cash sweep is offered as an account feature and service to facilitate the operation and maintenance of the account and is not intended to be used as an investment option or as part of an account’s asset allocation, though for certain advisory accounts, it is typical for an account to have an allocation to cash to support the operational needs and fees charged to the account. LPL and its financial professionals do not typically recommend specific sweep service options or underlying sweep holdings. For more information, please see your customer agreement and the applicable ICA, DCA, or SBICA disclosure booklet, or the sweep money market fund prospectus. The aggregate fees and expenses received by LPL in connection with the customer account’s designated sweep service option can be higher or lower than the customer’s yields on the sweep service option depending on the particular sweep option, prevailing interest rates and other market factors. See https://www.lpl.com/disclosures/lpl-financial-fdic-insured-bank-deposit- A 1 2 – 1 0 2 5 P a g e 1 3 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE sweep-programs.html for Information about our customer fees and customer Interest rates for ICA and DCA, or contact your IAR for information about our customer fees and customer interest rates for SBICA and for money market funds. Historically, customer yields in ICA have always been lower than the aggregate fees and charges received by LPL. Customer yields in DCA, SBICA and in money market mutual funds have been both lower and higher than the aggregate fees and charges received by LPL. Cash sweep services are not intended to be used for long-term investments and are more appropriately viewed as an indirect cost of maintaining and operating the account. LPL makes available a wide range of investment alternatives with differing risk and return characteristics, which are better suited for meeting customer investment needs and objectives. Customers should compare the terms, interest rates, required minimum amounts and other features of their account’s applicable sweep service option available through other types of accounts and investment options available in their account. FDIC insurance protects against the loss of FDIC-insured deposits if the depository institution or bank holding the deposit fails. LPL itself is not an FDIC-insured depository institution. With respect to our sweep service options, only balances received by, and deposited at, the ICA, DCA and SBICA participating banks are eligible for FDIC insurance (subject to applicable limits). Eligibility for pass-through deposit insurance coverage for ICA, DCA, and SBICA deposits is subject to fulfilling specific conditions. Client Cash Accounts and money market mutual funds are not customer bank deposits and are subject to investment risks, including the potential loss of the amount invested. These investments are not FDIC-Insured, but may be subject to SIPC protection. (cid:120) Insured Cash Account (ICA). LPL's ICA sweep service option automatically sweeps otherwise uninvested cash balances held within customer brokerage (and certain advisory accounts) into interest-bearing bank deposits eligible for FDIC insurance (subject to applicable limits). Under its agreement with each ICA participating bank in which customer cash may be swept, LPL receives a fee from the bank equal to a percentage of the average daily deposit balance held at the bank. Such fees differ among the participating banks depending on the current interest rate environment and/or any fee waivers made by LPL. The fee LPL receives is generally an average aggregate annual rate of up to 6% as applied across the deposits held at all of the ICA participating banks. Because the banks generally pay different amounts to LPL on account balances, fees received by LPL with respect to a specific customer account (and the account's cash holdings) may be higher or lower than this average percentage amount. The fees received by LPL from the ICA participating banks reduce the interest rate customers receive on their cash held through ICA. These fees are additional compensation to LPL for operating and maintaining the account and for LPL’s other services to the account. LPL has chosen to offer ICA as the sole sweep service option for certain account types, in part because of the additional compensation LPL earns from the use of ICA. In situations where customer cash balances allocated through ICA exceed the deposit availability at ICA participating banks, uninsured cash balances may be placed into an “overflow” Client Cash Account. Such balances are considered to be “free credit balances” and represent a direct liability of LPL to the customer. See below for information about how LPL is compensated on Client Cash Account balances. (cid:120) Deposit Cash Account (DCA). LPL's DCA sweep service option automatically sweeps otherwise uninvested cash balances held within certain advisory accounts into interest bearing bank deposits eligible for FDIC Insurance (subject to applicable limits). In the DCA program, each Bank pays compensation equal to a percentage of the average daily aggregated omnibus deposit balance held at the bank. This amount includes the fee for the third-party administrator, LPL’s per account fee, and interest payable to participating accounts. Such fees differ among the participating banks. Customers have no rights to the amounts paid by the DCA participating banks, except for interest actually credited to the customer account. However, amounts collected from the DCA participating banks during each period, less interest credited, will be allocated on a per-dollar, per-account basis and used to offset each customer’s monthly LPL account fee for providing the sweep services. In addition, part of the payment by the participating banks will be used to compensate the third-party administrator for its services. For its services under the DCA program, including making the platform available, LPL receives a per-account fee each month. The monthly fee is based on a fee schedule indexed to the current Federal Funds Target (FFT) Rate as detailed in the DCA Disclosure Booklet located on lpl.com. The current A 1 2 – 1 0 2 5 P a g e 1 4 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE fee can also be found at lpl.com. It is expected that this fee will be recouped from the DCA participating banks and will not be a fee directly applied to customer accounts. The fee LPL receives under the DCA program does not vary, and is not affected by the actual amounts held in the deposit accounts or in the customer’s account. LPL has chosen to offer DCA as the sole service option for certain account types, in part because of the additional compensation LPL earns from the use of DCA. In situations where customer cash balances in DCA exceed the deposit availability at DCA participating banks, uninsured cash balances may be placed into an “overflow” money market mutual fund. See below for further information about fees generated by cash balances maintained in the DCA “overflow” money market mutual fund. (cid:120) Single Bank Insured Cash Account (SBICA). For certain eligible customers participating in an LPL investment program associated with, or located at, certain banks LPL makes available the SBICA sweep service (and not the sweep service they might otherwise be eligible for, such as ICA). The SBICA sweep service functions like the ICA sweep service, except that otherwise uninvested customer account cash balances will be automatically swept into deposits eligible for FDIC insurance (subject to applicable limits) of the bank through which the investment program is offered, or in some situations, in a series of banks affiliated with the investment program bank. The banks participating in the SBICA have an agreement with LPL for financial professionals to offer brokerage and advisory services on their premises. This presents an additional conflict of interest because the financial professional is an employee of the bank that is also used for the sweep, and the bank benefits financially from the deposits. Under its agreement with each SBICA bank into which customer cash may be swept, LPL receives a fee from the bank equal to a percentage of the average daily deposit balance in the respective SBICA. The fee paid to LPL equals an average annual rate of up to 0.50% as applied across all deposit accounts taken in the aggregate. Because the SBICA participating banks generally pay different amounts to LPL on account balances, fees received by LPL with respect to a specific customer account (and the account's cash holdings) may be higher or lower than this average percentage amount. In some situations, LPL will receive no fee with respect to these deposits. The fees received by LPL from the SBICA participating bank(s) reduce the interest rate received by customers on their cash held through SBICA. These fees are additional compensation to LPL for operating and maintaining the account and for LPL's other services to the account. LPL has chosen to offer SBICA as the sole sweep service option for certain account types (and accounts sourced from the bank, bank premises or the bank employees acting as LPL financial professionals), in part, because of the broader business relationship that LPL has with the bank (and its affiliates) as well as the additional compensation LPL receives (if any). (cid:120) Client Cash Accounts – ICA Overflow Balances. LPL receives additional compensation and benefits from the customer cash balances maintained in the ICA overflow mechanism, referred to as Client Cash Account, which constitute free credit balances available for LPL use. LPL can use free credit balances to fund its ongoing operations subject to the limitations under SEC Rule 15c3-3. Pursuant to Rule 15c3-3, LPL can (i) deposit free credit cash balances into a segregated deposit account at its banks, thereby earning interest on the Client Cash Account balances deposited, or (ii) invest the cash balances in securities backed by the full faith and credit of the U.S. government, thereby making money on any yield generated by such securities. The amount LPL will earn from these sources will vary based on market forces and the contracts for deposit arrangements that LPL is able to secure with its banks. LPL may use both or either of these vehicles at its sole discretion. Any amounts LPL receives pursuant to these sources will be reduced by the interest payable, if any, to customers on such balances, and further reduced by the cost of borrowing any funds necessary to meet its reserve requirements under Rule 15c3-3. For example, LPL may earn interest or a return by investing in short- term U.S. Government or Agency instruments or by using these balances to fund margin loans to its customers at a lower funding cost than would otherwise be the case. Customers do not share in the returns or proceeds associated with LPL's use or investment of such free credit balances, which are expected to exceed the amount of any Interest paid to the customer for Client Cash Account balances. (cid:120) Money Market Mutual Fund Sweep Option. For customer accounts not eligible for ICA, DCA or SBICA, otherwise uninvested cash balances held in the account are automatically swept and invested daily into shares of a money market mutual fund. Currently, taxable and tax-exempt money market funds offered by J.P. Morgan Asset Management and A 1 2 – 1 0 2 5 P a g e 1 5 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE Federated Services Company, are available. LPL receives compensation in the form of servicing fees of up to 0.25% of customer assets invested in J.P. Morgan Asset Management money market funds and up to 0.35% of customer assets invested in Federated Services Company money market funds. These money market mutual funds generally pay higher 12b-1 fees than other money market funds that are not used for sweep services. The 12b-1 fees and the payer of such fees are set out in the prospectus of the money market mutual fund. LPL receives service and administrative fees relating to the support of the sweep program from the sponsors of these funds, ranging between 0.25% and 0.45% of the assets Invested In the money market funds. Such fees may be waived by the fund companies in their sole discretion. These payments are in addition to other fees (e.g., recordkeeping and 12b-1 fees) received by LPL, where applicable. LPL also receives fees of up to 0.45% for DCA “overflow” balances that are swept into the Goldman Sachs Asset Management Financial Square Government Fund, if any. The fees and the payer of such fees are set out in the prospectus of the money market fund. The compensation that LPL receives related to ICA, DCA (including from any ICA and DCA overflow mechanisms) and the Sweep Funds is in addition to the Account Fee that LPL and IAR receive with respect to the assets in the sweep investment. This compensation related to ICA, DCA and Sweep Funds is an important revenue stream and presents a conflict of interest to LPL because LPL has a financial benefit if cash balances are maintained in ICA, DCA or the Sweep Funds. However, the compensation LPL receives on ICA, and DCA and Sweep Funds is retained by LPL and is not shared with its IARs. In addition, LPL Research does not take into account this compensation when it makes decisions on a Portfolio’s allocation to cash. Collateralized Lending Arrangements LPL has partnered with certain banks to help facilitate clients’ access to non-purpose lines of credit collateralized by their investment accounts. Because of LPL’s arrangements with the banks participating in the program, clients may be limited in their ability to negotiate the most favorable loan terms. Clients are not required to use the banks in LPL’s program, and can work directly with other banks to negotiate loan terms or obtain other, potentially more favorable, financing arrangements. If a Client obtains a loan from a non-partner bank, he should notify his IAR of the amount of the line of credit. Clients should understand that the interest and additional fees paid to the bank in connection with the loan are separate from and in addition to the advisory fees the client pays LPL for its advisory services on the account. LPL receives third party compensation from participant banks based on the amount of outstanding loans. Compensation can be up to 0.75% of the outstanding loan amount. This compensation to LPL varies, and, therefore, LPL can earn more or less depending on the bank selected by the client. The receipt of compensation poses a conflict of interest to LPL because LPL has a financial incentive for the client to select a bank in the program, as well as a participating bank that pays LPL more than other participating banks. However, LPL does not share this compensation with its IARs, and therefore, an IAR does not have a financial incentive if one bank is selected over another. LPL and its IARs have an interest in continuing to receive investment advisory fees, which gives LPL and its IARs an incentive to recommend that clients borrow money rather than liquidate some of their assets managed by LPL and the IAR. This incentive creates a conflict of interest for LPL and its IARs when advising clients seeking to access funds on whether they should liquidate assets or instead hold their securities investments and utilize a line of credit secured by assets in their account. Because LPL and its IARs are compensated primarily through advisory fees paid on clients’ accounts, LPL and its IARs also have an interest in managing an account serving as collateral for a loan in a manner that will preserve sufficient collateral value to support the loan and avoid a bank call. This may present a conflict of interest with clients because it could incentivize LPL’s IARs to invest in more conservative, lower performing investments to maintain the stability of the account. For additional disclosures regarding LPL’s collateralized lending program, including a list of the banks currently participating in the program, please visit lpl.com/disclosures.html, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Third Party Compensation and Related Conflicts of Interest.” A 1 2 – 1 0 2 5 P a g e 1 6 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE Credit Cards As part of its cash management services, LPL makes available for its customers credit cards through a partner bank. LPL receives a flat fee for each new activated credit card that is used by the cardholder in the first 90 days. LPL also receives a portion of the transaction volume of the cardholder’s account. LPL’s portion of the transaction volume varies depending on the number of LPL active cardholder accounts. Rollovers If a client is a participant in an employer-sponsored retirement Plan, such as a 401(k) plan, and decides to roll assets out of the plan into an account at LPL, LPL and LPL IARs have a financial incentive to encourage client to invest those assets in client’s account, because LPL will be paid on those assets, for example, through advisory fees. Client should be aware that such fees likely will be higher than those a participant pays through an employer-sponsored plan, and there can be maintenance and other miscellaneous fees. As securities held in employer-sponsored plans are generally not transferrable to the client’s account, 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. This conflict of interest is mitigated by LPL’s policy regarding rollovers from an employer-sponsored plan into an LPL individual retirement account (“IRA”). LPL and LPL IARs may assist clients contemplating a rollover by providing general investment education to assist plan participants in making informed investment decisions about the distribution options available to them. LPL’s educational services are intended to be consistent with the Department of Labor’s Interpretive Bulletin 96-1. LPL is not acting in a fiduciary capacity under ERISA when providing educational services. The general investment education provided is not intended to be viewed or construed as a suggestion for client to take a particular course of action with respect to employer-sponsored plan assets (including, a distribution therefrom). With respect to employer-sponsored plan rollovers, LPL makes information available that outlines the many factors client should consider (including the types of fees and costs of an IRA and IRA investments) before making a decision. IARs may also agree to assist clients seeking a recommendation on whether to roll out of their employer-sponsored plan based on an analysis of the client’s personal financial needs, savings objectives and other financial and non-financial considerations, that is designed to determine whether such is in the client’s best interest under ERISA. IRA to IRA Transfers If LPL or an LPL IAR recommends that client move assets from an LPL brokerage IRA account or an IRA account held at another financial institution into the account, they are required to consider, based on the information client provides, whether client will be giving up certain investment-related benefits, such as the effects of breakpoints or rights of accumulation, and has determined that the recommendation is in client’s best interest because (1) greater services and/or other benefits (including discretionary management, trust services, holistic advice and planning, and automatic account rebalancing) can be achieved with the account; (2) access to your chosen financial professional and asset consolidation (in the case of a transfer from another financial institution) and (3) the asset based fees and transaction charges are justified by these services and features. Notwithstanding whether a recommendation has been made, clients should understand that with respect to any assets clients decide to move into the account, clients should: (1) evaluate the investment and non-investment considerations important to client in making the decision; (2) review and understand the fees and costs associated with the account; (3) recognize that higher net fees (if applicable) will reduce the client’s investment returns and ultimate retirement assets; and (4) understand the conflicts of interest raised by the financial benefits to LPL and its IARs resulting from the client’s decision to move assets into the account. Review of Accounts IARs review accounts and meet with clients, on a regular basis or as requested by the client, and such meetings may include review of accounts statements, performance information, and other information or data related to the client’s account and investment objectives. LPL provides clients with regular written reports regarding their accounts. LPL provides detailed performance information annually describing account performance and positions, with additional information available upon request. In addition, LPL A 1 2 – 1 0 2 5 P a g e 1 7 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE transmits to clients account statements showing transactions, positions, and deposits and withdrawals of principal and income. Portfolio values and returns shown in performance reports for the year-end time period may include mutual fund dividends paid out prior to December 31 but that were posted to the account within the first 2 business days of the subsequent year. The inclusion of such dividends in the year-end performance report may cause discrepancies between the report and the account statement client receives from LPL for the same period. Other Compensation LPL, LPL employees and IARs receive additional compensation, business entertainment and gifts from product sponsors. However, such compensation may not be tied to the sales of any products. Compensation includes such items as gifts valued at less than $100 annually, an occasional dinner or ticket to a sporting event, or reimbursement in connection with educational meetings, customer appreciation events or marketing or advertising initiatives, including services for identifying prospective clients. Product sponsors may also pay for, or reimburse LPL for the costs associated with, education or training events that may be attended by LPL employees and IARs, client events and LPL-sponsored conferences and events. LPL, LPL employees and IARs also receive reimbursement from product sponsors for technology-related costs, such as those to build systems, tools and new features to aid in serving customers. LPL employees provide sales support resources to IARs that use LPL advisory programs. The compensation that LPL pays to these employees varies based on the assets in LPL’s different advisory programs. These employees have an incentive to promote OMP to IARs over other advisory programs. These employees also earn more compensation when IARs transition client assets from brokerage accounts to advisory accounts, and have a financial incentive to encourage IARs to transition brokerage accounts to advisory. LPL receives compensation in the form of earnings on its short-term investment of cash in program accounts prior to the time the cash is invested for the account. These earnings are generally known as "float." Cash in the account would typically result from contributions to the account or sales of securities in the account. For accounts that opt out of the sweep program, the accounts may remain in free credit balances. In such case, LPL receives compensation in the form of earnings on cash. LPL does not share this compensation with your IAR. In the event a trade error occurs in the account, and such error is determined to be caused by LPL, LPL typically will cancel the trade and remove the resulting monetary loss to the client from the account. If a trade correction is required as a result of client (e.g., if client does not make full payment for purchases or fails to deliver negotiable securities for liquidations before trade settlement), LPL typically will cancel the trade and any resulting monetary loss will be borne by the client. In the case of a trade that requires a correction as described above and that resulted in a monetary gain to the client, such gain will be removed from the account and can result in a financial benefit to LPL. Conflicts Related to LPL Compensation to IAR The IAR recommending an advisory service receives compensation from LPL. In most cases, LPL has a compensation arrangement directly with the IAR. (In certain cases, LPL has entered into an agreement with a financial institution offering LPL’s advisory services on its bank or credit union premises, as described further below.) LPL typically compensates IARs pursuant to an independent contractor agreement and not as an employee. This compensation includes all or a portion of the advisory fee and, such portion received by IAR may be more than what IAR would receive at another investment advisor firm. All compensation paid to the IAR will be the sole responsibility of LPL and is payable by LPL out of the investment advisory fee clients pay to LPL. IARs have a financial incentive to negotiate fee arrangements that maximize their compensation. In some programs, LPL charges a negotiable advisory fee for itself plus a fee for third-party managers that is not negotiable. Differences in fees for third-party managers, and the absence of such fees in other programs, creates a conflict of interest for the IARs insofar as IARs can negotiate a higher LPL advisory fee for a program or strategy with lower or no separate manager fee than they could for an account subject to a higher third-party manager. The amount received by an IAR as a result of a client’s participation in any particular program offered A 1 2 – 1 0 2 5 P a g e 1 8 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE by LPL often is more than the IAR would have received if the client participated in other programs, paid third-party manager fees, or paid separately for investment advice, brokerage and other services covered by the account fee. Such compensation includes other types of compensation, such as bonuses, awards or other things of value offered by LPL to the IAR. In particular, LPL pays its IARs in different ways, for example: (cid:120) payments based on production (cid:120) equity awards from LPL’s parent company, LPL Financial Holdings Inc., consisting of awards of either restricted stock units (a promise to deliver stock in the future) or stock options to purchase stock, in each case subject to satisfaction of vesting and other conditions reimbursement or credits of fees that IARs pay to LPL for items such as administrative services, or technology fees free or reduced-cost marketing materials advances of advisory fees (cid:120) (cid:120) (cid:120) payments in connection with the transition of association from another broker-dealer or investment advisor firm to LPL (cid:120) (cid:120) payments in the form of repayable or forgivable loans (cid:120) attendance at LPL conferences and events. Some of these forms of compensation, particularly equity awards of LPL Financial Holdings Inc., give IARs a financial interest in the success of LPL. IARs who have a financial interest in the success of LPL have an incentive to recommend investments that are more profitable for LPL, regardless of whether the IARs share in that compensation directly. Note that LPL has a dedicated team of employee IARs in its offices who service certain accounts, and also a small subset of IARs who operate their own offices or are located on the premises of certain financial institutions and are employees of LPL Employee Services, LLC, an LPL-affiliated company. In such cases, the IARs are compensated as employees, and such compensation can include a salary, bonus and other things of value as set out above. LPL also charges IARs various fees under its independent contractor agreement, for example, for administrative, custody and clearing services to accounts, technology and licensing. In certain cases, LPL pays IARs this compensation, and charges IARs these fees, based on the IAR’s overall business production and/or on the amount of assets serviced in LPL advisory relationships. When compensation or fees charged is based on the level of production or advisory assets of an IAR, the IAR has a financial incentive to meet those production or asset levels. The amount of this compensation from LPL could be more, and the amount of these fees charged by LPL could be less, than what the IAR would receive, or pay, if he or she associated with another investment advisor firm. The level of compensation and costs is an incentive for an IAR to become associated with LPL over another investment advisor firm. This compensation the IAR receives from LPL could be more than if the client participated in other LPL programs, programs of other investment advisors or paid separately for investment advice, brokerage and other client services, and likewise, the fees that IAR pays to LPL could be less for OMP than other programs or services. In such cases, the IAR has a financial incentive to recommend advisory services in OMP over other programs and services. Although the IAR may factor in the fees charged to them by LPL in the overall Advisory Fee negotiated by the client, IAR can still earn more for offering OMP at a lower overall fee rate than the fee rate for a program offering a third-party manager. However, an IAR may only recommend a program or service that he or she believes is suitable and in the best interests of a client in accordance with the applicable standards under the Advisers Act or other applicable law. LPL also provides various benefits and/or payments to IARs that are newly associated with LPL to assist the IAR with the costs (including foregone revenues during account transition) associated with transitioning his or her business to LPL (collectively referred to as “Transition Assistance”). The proceeds of such Transition Assistance payments are intended to be used for a variety of purposes, including but not necessarily limited to, providing working capital to assist in funding the IAR’s business, satisfying any outstanding debt owed to the IAR’s prior firm, offsetting account transfer fees (ACATs) as a result of the IAR’s clients transitioning to LPL’s custodial platform, technology set-up fees, marketing and mailing costs, stationary and licensure transfer fees, moving expenses, office space expenses, staffing support and termination fees associated with moving accounts. The amount of the Transition Assistance payments is often significant in relation to the overall revenue earned or compensation received by the IAR at his or her prior firm. Such payments are generally based on the size of the IAR’s business established at A 1 2 – 1 0 2 5 P a g e 1 9 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE his or her prior firm, for example, a percentage of the revenue earned or eligible assets serviced by the IAR at the prior firm, and, in certain cases, on the amount of the IAR’s client assets that are transferred to LPL above an agreed-upon threshold. These payments are generally in the form of payments or loans to the new LPL IAR with favorable interest rate terms as permitted under applicable law, which are paid by LPL or forgiven by LPL based on years of service with LPL (e.g., if the IAR remains with LPL for 5 years) and/or the scope of business engaged in with LPL. LPL does not verify that any payments made are actually used for such transition costs. In addition, existing IARs are eligible to receive financial assistance from LPL in connection with transferring existing client accounts serviced at an approved third-party investment program to an on-platform LPL advisory or brokerage account (“Operational Assistance”). These payments are typically calculated as a percentage of assets transferred to LPL up to 0.15%, but in some cases may involve a flat amount up to $350 per transferred account, and are also generally payable in the form of payments or loans to the IAR that are forgivable based on years of service with LPL. While the loans are intended to offset bona fide time and effort incurred by IARs in identifying and coordinating transfers, the loans can create an incentive for IARs to recommend that clients transfer their assets to on-platform LPL advisory and brokerage accounts. However, an IAR may only recommend a program or service that he or she believes is suitable and in the best interests of a client in accordance with the standard of care under applicable law. The receipt of Transition Assistance or Operational Assistance creates a conflict of interest in that an IAR has a financial incentive to recommend that a client open and maintain an account with the IAR and LPL for advisory, brokerage and/or custody services, and to recommend switching investment products or services where a client’s current investment options are either not available through LPL or are maintained through a third-party investment program, in order to receive the Transition Assistance or Operational Assistance benefit or payment. LPL and its IARs attempt to mitigate these conflicts of interest by evaluating and recommending that clients use LPL’s services based on the benefits that such services provide to clients, rather than the Transition Assistance or Operational Assistance earned by any particular IAR. However, clients should be aware of this conflict and take it into consideration in making a decision whether to establish or maintain a relationship with LPL, or to transfer an existing third-party investment program account to LPL. If LPL makes a payment or loan to a new or existing IAR, there is also a conflict of interest because LPL’s interest in collecting on the payment or loan affects its ability to objectively supervise the IAR. Ownership Interest in Doing-Business-As (“DBA”) Entities Some IARs operate through independent practices with a separate Doing-Business-As (or “DBA”) designation. In some cases, LPL may partially or wholly own such practices, and have a financial interest in the business success of the DBA as a whole, or in a particular element of the DBA via specific ownership interests in its brokerage, advisory, insurance, or other financial services business (or any combination thereof). Clients should ask their IAR about the extent to which LPL has a financial interest in their practice. Client Referrals From time to time, LPL and/or its IARs enter into arrangements with clients, third parties or other financial intermediaries for lead generation, client referrals or solicitation for program accounts (collectively, “solicitation arrangements”). These solicitation arrangements range from largely impersonal referrals to specific client introductions to LPL and its IARs. Under solicitation arrangements, the third parties and financial intermediaries are independent contractors. In most cases, third parties are not advisory clients of LPL and do not refer clients based on their experience with LPL as advisory clients. The compensation paid under the solicitation arrangements is structured in various ways, including a one-time fee, a flat fee per lead or referral, and sharing a portion of the ongoing Account Fee. LPL and its IARs have generally entered into the following types of referral arrangements: (cid:120) Referral Networks. Some third parties operate referral networks. Referral networks may present potential clients with a list of possible investing firms and investment advisory representatives, or may direct potential clients specifically only to LPL and its IARs. Some referral networks receive a flat fee per referral and/or an ongoing fee, while others share a portion of the ongoing Account Fee; A 1 2 – 1 0 2 5 P a g e 2 0 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE (cid:120) Professional Cross Referrals. Some IARs have relationships with other professionals, such as accountants, lawyers or tax advisors, in which the professionals refer clients to IARs and in exchange the IARs refer clients to the professionals for their services. The cross-referral arrangement is a quid pro quo relationship that can give rise to similar conflicts as compensated referrals; (cid:120) Client Referral Awards. Investment advisory clients of LPL’s IARs refer new advisory clients to their IARs. Sometimes, in connection with these referrals, IARs pay their clients one-time, non-cash gifts like gift cards or tickets to events for the clients referring to them new advisory clients; (cid:120) Unaffiliated Financial Institutions. LPL and its IARs offer advisory services on the premises of unaffiliated financial institutions, like banks or credit unions. These financial institutions refer clients to LPL. See more about LPL’s relationship with financial institutions under “Unaffiliated Financial Institutions” below; and (cid:120) Other Arrangements. LPL and its IARs may enter into other arrangements in the future that provide for compensation similar to one or more of the types of arrangements described above. Depending on the solicitor’s arrangement with LPL, a solicitor may not be compensated for referring a client who opens a brokerage account rather than an advisory account, and as a result may encourage the client to open an advisory account instead of a brokerage account. Solicitation arrangements give rise to material conflicts of interest because the referring party has a financial incentive to introduce new investment advisory clients to LPL and its IARs. Solicitors may also have other conflicts of interest with respect to a particular IAR or may be associated with LPL in another way. Clients who are introduced to LPL and its IARs through a solicitation arrangement receive specific disclosures at the time of the introduction. If you receive such disclosures, you should review them carefully to understand the details of LPL’s arrangements with the person introducing you to LPL. LPL(cid:16891)s participation in these referral arrangements does not diminish its fiduciary obligations to its clients. Unaffiliated Financial Institutions LPL and its IARs offer advisory services on the premises of unaffiliated financial institutions, like banks or credit unions. When services are offered in a bank or credit union, the advisory services are offered by LPL and not the financial institution. Any securities recommended as part of the investment advice are not guaranteed by the financial institution, or insured by the Federal Deposit Insurance Corporation or any other federal or state deposit guarantee fund relating to financial institutions. LPL has entered into agreements with the financial institutions pursuant to which LPL typically shares compensation, including a portion of the Account Fee, with the financial institution for the use of the financial institution’s facilities and for client referrals. Instead of paying the IAR the portion of the Account Fee as described above, LPL may share the Account Fee with the financial institution, and the financial institution pays part of that amount to IAR. The financial institution establishes the compensation plan for the IAR, which is subject to approval by LPL. The compensation plan determines how the IAR’s compensation is structured. IAR will have a financial incentive to recommend a particular service or product if under the compensation plan the recommended product will result in more compensation to the IAR than another product or service, including advisory versus brokerage services. If an IAR is recommending an advisory program or service, he or she must believe that the program or service is suitable and in the best interests of the client in accordance with the applicable standards under the Advisers Act. In a few situations, LPL has agreements to provide similar services at financial institutions in which compensation is not shared with the financial institution. If IAR is an employee of the financial institution where it provides services to program accounts, LPL typically shares with the financial institution between 75% to 100% of the Account Fee, after LPL retains its portion of the Account Fee for its administrative services. IAR (an employee of the financial institution) will be compensated (e.g. in the form of salary, bonus, commissions, etc.) by the financial institution based on the specific agreement and/or compensation plan between the financial institution and the IAR. If IAR is not an employee of the financial institution where it provides services to program accounts, LPL typically shares directly with IAR, after deduction of LPL’s portion, between 25% to 100% of the Account Fee, and with the financial institution between 0% to 75%. All compensation paid to IAR or the financial institution will be the sole responsibility of LPL, and will not result in any increase in the Account Fees you pay to LPL. A 1 2 – 1 0 2 5 P a g e 2 1 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE Some of these financial institutions are affiliated with investment product sponsors (such as mutual fund sponsors) or offer certificates of deposit. An IAR located on the premises of a financial institution has a potential conflict of interest when IAR encourages clients to invest in that financial institution’s certificates of deposit or proprietary investment products, such as mutual funds and structured products. When an affiliated investment product is selected for an account, the financial institution receives a portion of the Account Fee pursuant to the agreement between LPL and the financial institution and its affiliate receives fees from the affiliated investment product. Because affiliates of the financial institution earn fees and other benefits from the affiliated product, the financial institution has an incentive to select its affiliated products based on the compensation and benefits its affiliates receive rather than on a client’s needs. In addition, because mutual funds benefit from scale, the financial institution and its affiliated companies have an interest in the mutual funds gaining greater assets. Certain financial institutions provide credits for affiliated investment products. We update this information from time to time on lpl.com/disclosures.html. For more information, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Third Party Compensation and Related Conflicts of Interest.” Note that the IAR does not receive additional compensation from the financial institution for selecting the affiliated products and the IAR may only recommend an investment product that he or she believes is appropriate for clients. LPL reviews and selects investment products for the Program and LPL may elect to remove or replace an investment product. There is a conflict of interest because the business relationship between LPL and the financial institution could affect LPL’s ability to objectively select and determine whether to continue to maintain these investment products in the Program. However, LPL only approves investment products that it determines are suitable and in the best interests of clients using the Program depending on clients’ investment objective and risk tolerance. LPL also provides other forms of compensation to financial institutions, such as bonuses, awards or other things of value offered by LPL to the institution. For example LPL pays financial institutions based on production, in the form of repayable or forgivable loans, reimbursement of fees that LPL charges for items such as administrative services, and other things of value such as free or reduced- cost marketing materials, transition assistance for changing association from another broker-dealer or investment advisor firm to LPL, advances of advisory fees, and/or attendance at LPL’s national conference or top producer forums and events. LPL may pay this compensation based on overall business production and/or on the amount of assets serviced in LPL advisory programs. Financial institutions are also eligible to receive Operational Assistance (as defined above) from LPL in order to assist with offsetting time and expense in coordinating transfers of client accounts from third party investment platforms to LPL’s platform. The compensation is typically calculated and payable to the institution as a percentage of assets transferred to LPL up to 0.15%, but in some cases may be a flat-dollar amount per transferred account with a maximum of up to $350 per account. The amount of this compensation may be more than what the financial institution would receive if the client participated in other LPL programs, programs of other investment advisors or paid separately for investment advice, brokerage and other client services. As a result, the financial institution and IAR have a financial incentive for the IAR to recommend the program account and services that will result in the greatest compensation to the financial institution and IAR. If LPL makes a loan to a new or existing financial institution, there is also a conflict of interest because LPL’s interest in collecting on the loan affects its ability to objectively supervise an IAR at that financial institution. In addition, financial institution employees who are not associated with LPL often refer prospective customers to IARs working in the financial institutions. Those employees frequently receive a nominal referral fee from the financial institution (typically up to $25) as compensation for each referral. Employees of trust departments at certain financial institutions are authorized under the terms of applicable trust arrangements to delegate investment management responsibility to LPL and to receive a portion of the compensation earned in connection with investment advisory services provided to these accounts through LPL. These amounts are negotiated and vary but often amount to a significant portion of the total fees paid for investment advisory services. Financial Information and Custody LPL is a qualified custodian as defined in Rule 206(4)-2 under the Advisers Act and maintains custody of OMP client funds and securities in a separate account for each client under the client’s name. LPL as a qualified custodian sends account statements A 1 2 – 1 0 2 5 P a g e 2 2 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE showing all transactions, positions, and all deposits and withdrawals of principal and income. LPL sends account statements periodically when the account has had activity or quarterly if there has been no activity. Clients should carefully review those account statements. Brokerage Practices In OMP, LPL requires that clients direct LPL as the sole and exclusive broker-dealer to execute transactions in the account. Clients should understand that not all advisors or program sponsors require their clients to direct brokerage. However, clients should understand that LPL is not paid a commission for executing transactions in OMP accounts and execution is made at the net asset value of the mutual fund. Although LPL is not paid a commission for transactions in the account, LPL charges a $5 transaction charge for each transaction (unless waived as described herein). Because LPL bears costs for each transaction made in an account, this presents a conflict of interest because these costs may be a factor LPL considers when deciding which securities to select and whether or not to place transactions in an account. However, LPL mitigates this conflict by compensating the team responsible for directing the trades through a bonus based on the performance of the portfolios; therefore, the team is not incentivized by cost reduction. LPL will aggregate transactions for a client with other clients. LPL also will aggregate rebalancing transactions for an account with other program accounts. Due to the large number of accounts that may be involved in rebalancing transactions on a single day, LPL may effect transactions for some accounts on one day and for other accounts on the following day or days. In such case, LPL will have discretion to sequence the accounts involved in rebalancing transactions with the goal of treating all accounts equitably over time. LPL will reinvest dividends in accordance with LPL’s Dividend Reinvestment Program (“DRP”). Some securities held in the Account may be ineligible for DRP, including securities not custodied at LPL Financial. There is no requirement to participate in the DRP, Client can enroll or unenroll at any time by contacting their IAR or LPL. DRP transactions will be confirmed on at least a quarterly basis as part of the regular periodic account statement. Additional important disclosures about DRP, including eligibility, fees, how dividends are reinvested, and more can be found at lpl.com/disclosures.html. Certain orders may be blocked or subject to review by LPL before they are directed to an exchange or market maker for execution. This review may result in a delay in execution. LPL reserves the right to place restrictions on your account in our sole discretion, and to cancel any order that we believe would violate federal credit regulations or other regulatory limitations; however, LPL will have no responsibility or liability for failing to cancel any order. Brochure Supplements Accompanying this Brochure are Brochure Supplements for individual employees or officers of LPL. Note that although these individuals are responsible for investment advice provided by LPL and may meet with clients from time to time, they are not IARs responsible for the ongoing individualized investment advice provided to a particular client. For more information about the IAR managing the account, client should refer to the Brochure Supplement for the IAR, which should have been provided by the IAR along with this Brochure at the time client opened the account. If client did not receive a Brochure Supplement for the IAR, the client should contact the IAR or LPL at lplfinancial.adv@lplfinancial.com. A 1 2 – 1 0 2 5 P a g e 2 3 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS March 31, 2025 1055 LPL Way Fort Mill, SC 29715 (704) 733-3300 www.lpl.com Marc Andrew Zabicki Louis James Carpenetti Garrett Fish Jason Hoody Kristian Kerr Jeffrey Roach Adam Turnquist Lawrence Dean Gillum Jina Yoon Quincy Krosby Thomas Shipp Craig Brown Scott Froidl Jeffrey Alan Buchbinder 201 Washington Street, Suite 300 Boston, MA 02108 (617) 423-3644 George Smith 4707 Executive Drive San Diego, CA 92121 (858) 450-9606 These Brochure Supplements provide information about certain LPL employees or officers that supplements the LPL Financial Brochure that is attached to these Brochure Supplements. Please contact LPL Financial at the number above if you did not receive the LPL Financial Brochure or if you have any questions about the contents of these Brochure Supplements. You may also contact your LPL investment advisor representative with questions. Additional information about these LPL employees or officers is available on the SEC’s website at https://adviserinfo.sec.gov/. Note that although these LPL employees or officers included in these Brochure Supplements are responsible for investment advice provided by LPL they are not the IARs responsible for the ongoing individualized investment advice provided to a particular client. For more information about the IAR managing the account, client should refer to the Brochure Supplement for the IAR, which should have been provided by the IAR along with the LPL Financial Brochure and these Brochure Supplements at the time client opened the account. If client did not receive a Brochure Supplement for the IAR, the client should contact the IAR or LPL at lplfinancial.adv@lplfinancial.com. Marc Andrew Zabicki Educational Background and Business Experience tying a portion of the compensation to Marc Zabicki was born in 1966. He has a BS in Economics from Florida State University and he is a Chartered Financial Analyst (CFA). He is Chief Investment Officer and the Director of Research for LPL Research and has been with the firm since 2020. Prior to joining LPL, he was Chief Investment Officer at Bower Hill Capital Management. Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and the outperformance of all LPL managed portfolios. Disciplinary Information Supervision None. Other Business Activities Mr. Zabicki is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation Mr. Zabicki is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs, and he reports to Rob Pettman, Executive Vice President. The advice provided by Mr. Zabicki is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The Chief Compliance Officer (“CCO”), Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Mr. Zabicki receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 1 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS Louis James Carpenetti Educational Background and Business Experience is a Senior Vice President and Head of Model Portfolio Management at LPL and joined LPL in 2022. Prior to joining LPL, Mr. Fish was a Portfolio Manager at JPMorgan Asset Management. Disciplinary Information None. Other Business Activities Louis James Carpenetti was born in 1971. He has a BS in Management from Palm Beach Atlantic University, an MBA from Georgia College & State University, a CFA Charterholder and has earned the CFP® certification. He is a Senior Vice President of Trading at LPL and joined LPL in July 2021. Prior to joining LPL, Mr. Carpenetti was Managing Director for Truist for 22 years serving in a variety of management and trading capacities. Disciplinary Information Mr. Fish is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. None. Additional Compensation Other Business Activities Mr. Carpenetti is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation tying a portion of the compensation to Mr. Fish receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, the and outperformance of all LPL managed portfolios. Supervision tying a portion of the compensation to Mr. Carpenetti receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, the and outperformance of all LPL managed portfolios. Supervision Mr. Fish reports to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Fish is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Jason Hoody Educational Background and Business Experience As a Senior Vice President, Mr. Carpenetti is responsible for trade execution in LPL’s advisory programs, subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Garrett Fish Educational Background and Business Experience Jason Hoody was born in 1975. He has a BS in Political Science from Clarkson University, an MA in International Affairs from American University, an MS in Finance from Johns Hopkins University, and is a CFA Charterholder. He is a Senior Vice President in Research at LPL and joined LPL in 2015. Prior to joining LPL, he was a Vice President at BB&T and an analyst at KPMG. Garrett Fish was born in 1969. He has a BA in Japanese History from Bates College and is a CFA Charterholder. He B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 2 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS Additional Compensation Disciplinary Information None. Other Business Activities None. Additional Compensation tying a portion of the compensation to Mr. Kerr receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and the outperformance of all LPL managed portfolios. Supervision tying a portion of the compensation to Mr. Hoody receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, the and outperformance of all LPL managed portfolios. Supervision Mr. Kerr reports to Mr. Zabicki, the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Kerr is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Jeffrey Roach Educational Background and Business Experience in 1973. He has a BS Mr. Hoody reports to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Hoody is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Kristian Kerr Educational Background and Business Experience in 1977. He has a BBA Jeffrey Roach was born in Mathematics from Bob Jones University and a MA and PhD in Economics from Clemson University. He is Chief Economist at LPL and joined LPL in 2022. Prior to joining LPL, Dr. Roach was Senior US Economist for Visa Inc, Managing Director, Economist at MacroView Partners and Chief Economist at Horizon Investments. Disciplinary Information None. Other Business Activities Kristian Kerr was born in International Business from Schiller International University in Madrid, Spain. He is a Senior Vice President and the Head of Macro Strategy at LPL and joined LPL in 2023. Prior to joining LPL, Mr. Kerr worked at Citi Private Bank as the Western Region Head of Foreign Exchange & Macro. Disciplinary Information None. Dr. Roach is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Other Business Activities Additional Compensation Mr. Kerr does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Dr. Roach receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 3 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS capping the amount of compensation paid regardless of the return, and tying a portion of the compensation to the outperformance of all LPL managed portfolios. Supervision tying a portion of the compensation to Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and the outperformance of all LPL managed portfolios. Supervision Mr. Turnquist reports up to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Turnquist is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Lawrence Dean Gillum Educational Background and Business Experience Dr. Roach reports to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Dr. Roach is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Adam Turnquist Educational Background and Business Experience Lawrence Gillum was born in 1974. He has a BS from University of Florida and a Master in Business Administration from the University of North Carolina, Keenan Flagler Business School. He is a Vice President of Research at LPL and joined LPL in 2021. Prior to joining LPL, Mr. Gillum served as a Director at Raymond James where he oversaw fixed income research within the firm’s discretionary model platform. Disciplinary Information Adam Turnquist was born in 1984. He has a BS from the University of Minnesota-Duluth and an MBA from the University of St. Thomas. He is Chief Technical Strategist and joined LPL in 2022. Prior to joining LPL, Mr. Turnquist worked as a Vice President, Technical Research Analyst at Piper Sandler. None. Disciplinary Information Other Business Activities None. Other Business Activities Mr. Gillum is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation is a registered representative of LPL. Mr. Turnquist However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation Mr. Gillum receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, Mr. Turnquist receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short- term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 4 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS tying a portion of the compensation to the Supervision and outperformance of all LPL managed portfolios. Supervision Ms. Yoon reports up to Mr. Zabicki, the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Ms. Yoon is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Quincy Krosby Educational Background and Business Experience Mr. Gillum reports up to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Gillum is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Jina Yoon Educational Background and Business Experience Quincy Krosby was born in 1948. She has an MPhil and PhD from The London School of Economics. She is Chief Global Strategist at LPL and joined LPL in 2022. Prior to joining LPL, Ms. Krosby worked at Prudential Financial as Chief Market Strategist. is Chief Alternate Disciplinary Information None. Other Business Activities Jina Yoon was born in 1983. She has a BS and MEng from Investment Cornell University. She Strategist at LPL and joined LPL in 2023. Prior to joining LPL, Ms. Yoon was the Head of Portfolio Management & Senior Portfolio Manager at Nomura Private Capital. Prior to Nomura, she served both Institutional and Private Wealth Clients as the Head of Tactical Strategies at Credit Suisse. Disciplinary Information None. Ms. Krosby is a registered representative of LPL. However, she does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Other Business Activities Additional Compensation Ms. Krosby receives a regular salary. Supervision Ms. Yoon does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation Ms. Krosby reports to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. This is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Ms. Yoon receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short- term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and tying a portion of the compensation to the outperformance of all LPL managed portfolios. B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 5 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS Thomas Shipp Educational Background and Business Experience University and a MAIS in Computational Social Science from George Mason University. He is a Vice President and Head of Quant Strategy at LPL and joined LPL in 2021. Prior to joining LPL, Mr. Brown was a Senior Associate in Investment Analytics and Data at Dimensional Fund Advisors. Disciplinary Information None. Thomas Shipp was born in 1984. He has a BS in Business Administration from Fordham University and is a CFA Charterholder. He is a Vice President and Head of Equity Research at LPL and joined LPL in 2017. Prior to joining LPL, Mr. Shipp was an Associate in the Equity Research Department at BMO Capital Markets. Other Business Activities Disciplinary Information None. Mr. Brown does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Other Business Activities Additional Compensation Mr. Shipp is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation Mr. Brown receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short- term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and tying a portion of the compensation to the outperformance of all LPL managed portfolios. Supervision Mr. Shipp receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short- term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and tying a portion of the compensation to the outperformance of all LPL managed portfolios. Supervision Mr. Brown reports to Mr. Zabicki, the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Brown is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Scott Froidl Educational Background and Business Experience Mr. Shipp reports to Mr. Zabicki, the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Shipp is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Craig Brown Educational Background and Business Experience Scott Froidl was born in 1971. He has a BS from Lindenwood University. He is an Assistant Vice President Senior Investment Analyst at LPL and joined LPL in 2021. Prior to joining LPL, Mr. Froidl was a Senior Investment Analyst at Wells Fargo from 2018 until 2021 and Senior Investment Analyst at Stifel in 2018 while starting with the firm in 2001. Craig Brown was born in 1988 He has a dual BS in Economics and Information Analysis from James Madison B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 6 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS Other Business Activities Disciplinary Information None. Other Business Activities Mr. Buchbinder is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation Mr. Froidl is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation tying a portion of the compensation to Mr. Buchbinder receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, the and outperformance of all LPL managed portfolios. Supervision Mr. Froidl receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short- term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and tying a portion of the compensation to the outperformance of all LPL managed portfolios. Supervision Mr. Buchbinder reports up to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Buchbinder is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. George Smith Mr. Froidl reports to Mr. Zabicki, the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Froidl is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Educational Background and Business Experience Jeffrey Alan Buchbinder in 1983. He has a BS Educational Background and Business Experience in George Smith was born Mathematics from the University of Bristol in the United Kingdom (UK). He is Portfolio Strategist at LPL and joined LPL in 2013. Prior to joining LPL, Mr. Smith worked in London, UK for Legal and General Investment Management (LGIM) and Goldman Sachs Asset Management (GSAM). Disciplinary Information None. Jeffrey Alan Buchbinder was born in 1971. He has a BA in Economics from Northwestern University and an MBA from Duke University. He is Chief Equity Strategist and Portfolio Manager for LPL Financial Research and has been with the firm since 2003. Prior to joining LPL, he served as an Equity Research Associate at Sanford C. Bernstein. Prior to Bernstein, he was an Equity Research Associate at Deutsche Bank. Other Business Activities Disciplinary Information None. Mr. Smith is a registered representative of LPL. However, he does not engage in the sale of securities or receive B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 7 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS commissions or other compensation based on the sale of securities or other investment products. Additional Compensation Mr. Smith receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short- term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and tying a portion of the compensation to the outperformance of all LPL managed portfolios. Supervision Mr. Smith reports up to Mr. Zabicki, the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Smith is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877- 7210. B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 8 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C 

OPTIMUM MARKET PORTFOLIOS (OMP) PROGRAM BROCHURE LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 October 22, 2025 This program brochure provides information about the qualifications and business practices of LPL Financial (“LPL”). If you have any questions about the contents of this brochure, please contact LPL at lplfinancial.adv@lplfinancial.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about LPL also is available on the SEC’s website at https://adviserinfo.sec.gov. ITEM 1 COVER PAGE ITEM 2 MATERIAL CHANGES The following is a summary of certain changes made to this Brochure from the time of the most recent annual update dated March 28, 2024. Item 6 was updated to provide that effective November 24, 2025, LPL will be responsible for voting proxies solicited by, or with respect to, the issuers of any securities held in the account, except to the extent otherwise prohibited by law and unless clients opt to retain voting responsibility. Additional risk disclosures were added in Item 6 related to third-party service providers’ or any counterparties’ potential use of artificial intelligence and machine learning. Item 9 was updated to provide information regarding disciplinary events involving (i) a settlement with the SEC that included a $50 million fine for failing to maintain required records of certain business-related communications; and (ii) a settlement with the SEC that included an $18 million fine for LPL not following its anti-money laundering policies for its customer identification program and ongoing customer due diligence obligations. Item 9 was also updated to reflect the following setup fee charges payable to LPL by model managers or product sponsors, if applicable to the program: (i) a yearly $5,000 per strategy fee for annual due diligence reviews and maintenance; (ii) the one-time sponsor-level mutual fund setup fee was reduced from $40,000 to $15,000, with the per-fund setup fee increasing from $5,000 to $7,500; (iii) up to $15,000 as a sponsor level due diligence fee for exchange traded products; and (iv) a $5,000 per-trust fee for each unit investment trust. In addition, Item 9 was updated to disclose conflicts related to LPL’s decision to make certain product sponsors available on the applicable platforms when certain sponsors reimburse LPL for technology development related costs associated with the launch or maintenance of a platform, tool, or service. Item 9 was also updated to disclose risks related to LPL’s ability to block or review client orders before they are directed to an exchange or market maker for execution. This may result in a delay in execution, which could cause (i) a difference between execution price and the displayed quote at the time the order was entered; and (ii) a limit order becoming ineligible for execution. Item 9 was also updated to include additional information about LPL’s Dividend Reinvestment Program (DRP). ITEM 3 TABLE OF CONTENTS ITEM 1 COVER PAGE ............................................................................................................................................. 1 ITEM 2 MATERIAL CHANGES ............................................................................................................................... 1 ITEM 3 TABLE OF CONTENTS .............................................................................................................................. 1 ITEM 4 MATERIAL SERVICES, FEES AND COMPENSATION ................................................................................ 2 ITEM 5 ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ............................................................................ 5 ITEM 6 PORTFOLIO MANAGER SELECTION AND EVALUATION........................................................................ 5 ITEM 7 CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS .......................................................... 8 ITEM 8 CLIENT CONTACT WITH PORTFOLIO MANAGERS ................................................................................. 8 A 1 2 – R – 1 0 2 5 P a g e 1 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE ITEM 9 ADDITIONAL INFORMATION .................................................................................................................... 8 ITEM 4 MATERIAL SERVICES, FEES AND COMPENSATION Services LPL sponsors various types of advisory programs, including wrap fee programs, an advisor-enhanced digital advice program, and mutual fund asset allocation programs. LPL makes these programs available to clients directly and also through third party investment advisor firms (“Advisor”) and their associated persons. This Brochure provides a description of LPL’s Optimum Market Portfolios (“OMP”) program when offered through an Advisor. For more information about LPL’s advisory services and programs other than OMP, please contact your Advisor for a copy of a similar brochure that describes such service or program or go to https://adviserinfo.sec.gov. The OMP program is a professionally managed mutual fund asset allocation program in which LPL and Advisor provide ongoing investment advice. The Advisor obtains the necessary financial data from the client, assists the client in determining the suitability of the program and assists the client in setting an appropriate investment objective. The Advisor on a discretionary or non- discretionary basis selects a model portfolio of mutual funds (“Portfolio”) designed by LPL’s Research Department consistent with the client’s stated investment objective. If client authorizes Advisor to take discretion to select Portfolios on behalf of client, such authority will be set out in the Account Agreement and Application signed by the client. The Portfolios are made up of mutual funds in the Optimum Funds mutual fund family. A Portfolio may include up to six Optimum Funds. LPL has discretion to buy and sell securities in the account and will invest the account based on the Portfolio selected. The client authorizes LPL to take discretion by executing the Account Agreement and Application. LPL rebalances accounts based on the allocations in the Portfolio as described below. LPL reviews the account for rebalancing on the frequency selected by the client at account opening or as altered by the Advisor or the client from time to time. The choices for frequency of rebalancing are quarterly (four times per year), semi-annually (two times per year) or annually (once per year). Accounts are reviewed on the frequency selected based on the anniversary date of account opening to determine if rebalancing is necessary. An additional rebalance may be requested outside of the scheduled frequency once every 12 months. At each rebalancing review date, accounts are rebalanced if the Account has available cash for investment and at least one of the account positions is outside a range determined by LPL, subject to a minimum transaction amount established by LPL in its discretion. In addition, LPL may review the account for rebalancing in the event that LPL Research changes the model portfolio. All recommendations by LPL regarding accounts in the OMP program will be in an advisory capacity. LPL may accommodate requests by client or Advisor for all or a portion of the assets in the account to remain allocated to cash for a period of time. Such customized Portfolio requests, liquidation requests in connection with withdrawals, and changes to the Portfolio or investment objective selected may take up to 5 business days to process, and, in certain circumstances, may take longer. LPL invests deposits in an account according to the Portfolio, but such deposits (or a portion thereof) may be liquidated and the proceeds may remain in cash until certain conditions are met related to trade size and position deviation from the target allocation. Although OMP accounts are not considered tax efficient or tax managed, LPL may delay placing transactions on non-retirement accounts by one day for any rebalancing scheduled to occur on the first one year anniversary date of the account opening in an attempt to limit the tax treatment of realized short-term gains for any position being sold. LPL may also apply discretion to deviate from the model portfolios in accounts, in which it is not possible or impractical to be invested in all of a model’s holdings, for example in smaller accounts. In connection with the program, LPL also acts as custodian to accounts, provides research information to Advisor, provides brokerage services as the broker-dealer on transactions, and performs administrative services, such as performance information. Fee Schedule Clients in the OMP program pay LPL and Advisor an annualized fee (“Account Fee”) for the asset management services of LPL and Advisor, as well as the administrative and custodial services of LPL. The Account Fee is shared with the Advisor. The Account Fee is negotiable between the client and the Advisor and is based on the value of assets in the Account, including cash holdings, and payable quarterly in advance. The maximum Account Fee is 2.50%. Upon request, the Account Fee also may be structured on a A 1 2 – R – 1 0 2 5 P a g e 2 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE tiered basis, with a reduced percentage rate based on reaching certain thresholds. LPL reserves the right to increase the upper limit of the Advisory Fee and/or Manager Fee range(s) upon 30 days’ prior notice to clients. LPL, Advisor, and IARs do not charge performance-based fees to accounts in the OMP program. LPL may retain a portion of the Account Fee for its administrative and custodial services. LPL shares up to 100% (typically between 90% to 100%) of the remaining portion of the Account Fee with the Advisor based on the agreement between LPL and Advisor. How the Account Fee is Charged LPL deducts the Account Fee and other fees and charges associated with an OMP account from the account. LPL calculates and deducts the Account Fee in the method described in the Account Agreement, unless other arrangements are made in writing. If a client wishes to be billed for the Account Fee, rather than a deduction directly from the account, the client needs to make a request to LPL through the Advisor. Payment in Advance and Refund of Pre-Paid Fees LPL deducts the Account Fee quarterly in advance. If the Account Agreement is terminated before the end of the quarterly period, LPL will pay the client a prorated refund of any pre-paid quarterly Account Fee based on the number of days remaining in the quarter after the termination date. However, if the account is closed within the first six months by the client or as a result of withdrawals that bring the account value below the required minimum, LPL and Advisor reserve the right to retain the pre- paid quarterly Account Fee for the current quarter in order to cover the administrative costs of establishing the account (for example, the costs related to transferring positions in and out of the account, data entry in opening the account, reconciliation of positions in order to issue performance information, and re-registration of positions). Other Types of Direct Fees and Expenses of LPL Clients also pay LPL other additional miscellaneous administrative or custodial-related fees and charges that apply to an OMP account. LPL notifies clients of these charges at account opening and makes available a current list of these charges on its website at lpl.com/disclosures.html. These fees include retirement account fees and termination fees, including, for example, a fee for loans processed for qualified retirement plan and 403(b)(7) plan accounts and an account termination fee for processing a full account transfer to another financial institution. These charges are not directly based on the costs of the transaction or service by LPL, may include a profit to LPL, and certain of the fees may be lowered or waived for certain clients. Fees Charged by Third Parties, Including the Optimum Funds There are other fees and charges that are imposed by third parties other than LPL that apply to investments in OMP accounts. In OMP, assets are invested in mutual funds and, therefore, there are two layers of advisory fees and expenses for those assets. As a shareholder of a Fund, Client will pay an advisory fee to the investment advisor of the Optimum Funds and other expenses charged by the Funds. Client will also pay LPL and Advisor the Account Fee with respect to assets invested in the Funds. The Optimum Funds or funds with similar investment objectives may be purchased directly outside of the Program. Therefore, clients could generally avoid the second layer of fees by not using the advisory services of LPL and Advisor and by making their own decisions regarding mutual fund investing. The amount of the advisory fees and other expenses of the Optimum Funds are set out in the prospectus and financial statements of the Optimum Funds, which are available upon request from Advisor or the Optimum Funds directly. Clients should understand that in many cases the mutual funds and mutual fund share classes offered through the Program charge higher fees and expenses than those that are not offered through the Program, and such other mutual funds and share classes may be equally or more appropriate for a client’s account. As discussed below, Client should understand that a portion of the fees and expenses Client pays as a shareholder of the Optimum Funds is used by the sponsor of the Funds to pay LPL for services LPL provides with respect to the funds. See Item 9, “Participation or Interest in Client Transactions,” for more information on the payments received by LPL with respect to the Optimum Funds. Other financial services firm may offer the same mutual funds that are offered through the Program but at lower overall costs to investors than the costs that clients incur by investing through the Program. A 1 2 – R – 1 0 2 5 P a g e 3 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE Advisor may charge fees in addition to the Account Fee. Clients should refer to the Firm Brochure of Advisor for more information regarding fees charged by Advisor. If client transfers into an OMP account a previously purchased mutual fund, and there is an applicable contingent deferred sales charge on the fund, client will pay that charge when the mutual fund is sold. If the account is invested in a mutual fund that charges a fee if a redemption is made within a specific time period after the investment, client will be charged a redemption fee. Depending on the share class and fee structure of the previously purchased mutual fund, LPL can receive fees such as 12b-1 fees from the previously purchased mutual fund until the position is liquidated and subsequently invested according to the OMP model. Any 12b-1 fees paid to LPL by mutual funds transferred into an account will be credited to the client’s account. If a mutual fund has a frequent trading policy, the policy can limit a client’s transactions in shares of the fund (e.g., for rebalancing, liquidations, deposits or tax harvesting). Decisions regarding the sale of mutual funds in an account may be made by LPL without regard to whether a client will be assessed a redemption fee. Clients can find more information regarding the fees and expenses of a mutual fund or ETF in the fund’s prospectus, which is available upon request from the IAR or directly from the fund. When transferring securities into an OMP account, client should be aware that certain securities are not be eligible for the account. In such case, the securities may be rejected, sold after the transfer, or moved to a brokerage account. Note that when an ineligible security is transferred into an account and subsequently sold or moved to a brokerage account, the advisory fee will be charged on such asset for the period of time the security was held in the account. Client should be aware that securities transferred into an account may have been subject to a commission or sales load when the security was originally purchased. After transfer into an OMP account, client should understand that an advisory fee will be charged based on the total assets in the account, including the transferred security. When transferring securities into an account, client should consider and speak to IAR about whether: (cid:120) (cid:120) (cid:120) a commission was previously paid on the security; client wishes for the security to be managed as part of the account and be subject to an advisory fee; or client wishes to hold the security in a brokerage account that is not managed and not subject to an advisory fee. Important Things to Consider About Fees on an OMP Account type and size of the account (cid:120) The Account Fee is a single fee for investment advisory services and other administrative and custodial services. Clients do not pay a commission or transaction charge to LPL. The Account Fee may cost the client more than purchasing the program services separately, for example, paying an advisory fee plus commissions or transaction charges to a broker-dealer for each transaction in the account. Factors that bear upon the cost of the account in relation to the cost of the same services purchased separately include the: (cid:120) (cid:120) historical and or expected size or number of trades for the account, and (cid:120) number and range of supplementary advisory and client-related services provided to the client. (cid:120) The Account Fee may be higher than the fees charged by other investment advisors for similar services. This is the case in particular if the Account Fee is at or near the maximum Account Fee set out above. The Advisor is responsible for determining the Account Fee to charge each client based on factors such as total amount of assets involved in the relationship and the complexity, number and range of supplementary advisory and client-related services to be provided to the account. Clients should consider the level and complexity of the advisory services to be provided when negotiating the Account Fee with Advisor. (cid:120) The Advisor recommending the program to the client receives compensation as a result of the client’s participation in the program. This compensation includes a portion of the Account Fee and also may include other compensation, such as bonuses, awards or other things of value offered by LPL to the Advisor. LPL pays this compensation based on the Advisor’s overall business production and/or on the amount of assets serviced in LPL advisory programs, including OMP. In particular, in certain cases, LPL pays an Advisor more compensation when providing services to an OMP account than other types of LPL advisory program accounts. Therefore, the amount of compensation from LPL can be more than what Advisor would A 1 2 – R – 1 0 2 5 P a g e 4 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE receive if the client participated in other LPL advisory programs, programs of other investment advisors or paid separately for investment advice, brokerage and other client services. Therefore, the Advisor may have a financial incentive to recommend an OMP account over other programs and services. (cid:120) The investment products available to be purchased in the program can be purchased by clients outside of an OMP account, through broker-dealers or other investment firms not affiliated LPL. (cid:120) Clients should consider the impact of fees and expenses on their investment portfolio, as described in the informational brochure titled “How Fees and Expenses Affect Your Portfolio” on lpl.com/disclosures.html under “Investor Regulatory & Educational Resources.”(cid:3) ITEM 5 ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS LPL generally requires a minimum account value of $1,000, but eligible contribution within the previous 365 days, including transfers, wires, checks, ACH or journal, are required for account sizes below $10,000. In certain instances, LPL will permit a lower minimum account size. An account will not be invested according to the Portfolio until the minimum has been reached. The program is available for individuals, individual retirement accounts (“IRAs”), banks, thrift institutions, credit unions, pension and profit sharing plans, including plans subject to Employee Retirement Income Security Act of 1974 (“ERISA”), trusts, estates, charitable organizations, state and municipal government entities, corporations and other business entities. ITEM 6 PORTFOLIO MANAGER SELECTION AND EVALUATION In OMP, LPL does not select, review or recommend the services of other investment advisor or portfolio management firms. LPL and Advisor are responsible for the investment advice and management offered to clients, and the client selects the Advisor who services the account. Advisor is responsible for determining the standards required for its associated persons. For more information about the Advisor, client should refer to the Advisor’s Firm Brochure, which client should have received at the time client opened the account. In OMP, clients invest in Portfolios designed by LPL’s Research Department. LPL Research designs different types of Portfolios for OMP to meet the varying needs of clients. The Advisor, or the client with the assistance of the Advisor, selects the Portfolio and provides advice based on the client’s individual needs. LPL’s Research Department uses the following investment strategies in designing Portfolios. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. Investing in securities involves the risk of loss that clients should be prepared to bear. Each of these investment strategies seek to generate capital appreciation while assuming a reasonable amount of risk. (cid:120) Standard. These Portfolios invest in up to six Optimum Funds across the following asset classes: large growth, large value, small/mid growth, small/mid value, international, and fixed income. (cid:120) U.S. These Portfolios invest in up to five Optimum Funds across the following asset classes: large growth, large value, small/mid growth, small/mid value, and fixed income. These Portfolios do not invest in international. (cid:120) Growth Tilt. These Portfolios invest in up to six Optimum Funds across the following asset classes: large growth, large value, small/mid growth, small/mid value, international, and fixed income. These Portfolios are over-weighted to growth relative to the standard models. (cid:120) Value Tilt. These Portfolios invest in up to six Optimum Funds across the following asset classes: large growth, large value, small/mid growth, small/mid value, international, and fixed income. These Portfolios are over-weighted to value relative to standard models. For Standard and U.S. Portfolios described above, LPL Research makes available a strategic or tactical version for each Portfolio. The strategic Portfolios are intended to take advantage of market opportunities that will occur or persist over a three-to-five-year time frame. The tactically managed Portfolios are intended to take advantage of short-, medium-, or long-term opportunities. In addition, for the Standard Portfolios there are two different versions of the tactically-managed portfolios: Traditional Standard and Spectrum Standard. The asset allocation of the Traditional Standard Portfolios is set primarily leveraging the LPL Research macroeconomic views. The asset allocation of the Spectrum Standard Portfolios is set primarily leveraging the LPL Research diligence views. A 1 2 – R – 1 0 2 5 P a g e 5 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE Types of Investments and Risks Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some risks associated with investing. (cid:120) Market Risk. This is the risk that the value of securities owned by an investor may go up or down, sometimes rapidly or (cid:120) unpredictably, due to factors affecting securities markets generally or particular industries. Interest Rate Risk. This is the risk that fixed income securities will decline in value because of an increase in interest rates; a bond or a fixed income fund with a longer duration will be more sensitive to changes in interest rates than a bond or bond fund with a shorter duration. (cid:120) Economic Conditions Risk. This is the risk that economic, political or financial developments will, from time to time, result in periods of volatility or other adverse effects that could negatively impact your account. (cid:120) Credit Risk. This is the risk that an investor could lose money if the issuer or guarantor of a fixed income security is unable (cid:120) or unwilling to meet its financial obligations. Investment Company Risk. To the extent a client account invests in ETFs or other investment companies, its performance will be affected by the performance of those other investment companies. Investments in ETFs and other investment companies are subject to the risks of the investment companies’ investments, as well as to the investment companies’ expenses. If a client account invests in other investment companies, the client account may receive distributions of taxable gains from portfolio transactions by that investment company and may recognize taxable gains from transactions in shares of that investment company, which would be taxable when distributed. (cid:120) Pledging Assets. LPL has partnered with certain banks to help facilitate clients’ access to collateralized non-purpose lines of credit; however, clients are not required to use the banks in LPL’s program, and can work directly with other banks (“non- partner banks”) to negotiate loan terms or obtain other financing arrangements. Clients who choose to use non-partner banks should notify Advisor of the amount of the line of credit. In these collateralized lending arrangements, clients borrow from the bank and pay interest to the bank. In some cases, Advisor may recommend that a client seeking to access funds (for purposes other than purchasing securities) hold his securities investments and instead utilize a non-purpose line of credit collateralized by the assets in his advisory account. Unless Advisor specifically recommends that a client hold his securities investments and instead utilize a collateralized line of credit to access funds, the decision regarding whether to arrange for a collateralized loan and the decision to draw down on such a loan are not covered by a client’s advisory relationship with LPL or Advisor. While Advisor may assist the client with facilitating a line of credit, clients are responsible for independently evaluating the terms of the loan and deciding whether the loan meets their needs. Clients also should be aware that pledging assets in an account to secure a loan involves additional risks. The bank holding the loan has the authority to liquidate all or part of the securities at any time without your prior notice in order to maintain required maintenance levels, or to call the loan at any time. As a practical matter, this may cause you to sell assets and realize losses in a declining market. Moreover, Advisor’s ability to make investment decisions or recommendations for the account may be restricted by collateral requirements imposed by the bank. These restrictions or a forced liquidation may interfere with your long term investment goals and/or result in adverse tax consequences. Further, you should note that the returns on accounts or on pledged assets may not cover the cost of loan interest and advisory fees. Clients should be aware that LPL’s collateralized loan program is one way, among many, for clients to raise necessary cash. Before pledging assets in an account, clients should carefully review the loan agreement, loan application and any forms required by the bank and any other forms and disclosures provided by LPL. For a list of the banks currently participating in LPL’s collateralized lending program, please visit lpl.com/disclosures.html, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Third Party Compensation and Related Conflicts of Interest.” (cid:120) Cybersecurity Risk. Failures or breaches of the electronic systems of LPL, its service providers, securities market participants or the issuers of securities can cause significant losses for investors. Unintentional cyber events, such as the inadvertent release of confidential information, could also adversely impact investor account. Any cyber event could cause result in the loss or theft of investor data or cause investors financial loss and expense. (cid:120) Use of Artificial Intelligence and Machine Learning. Recent technological advances in artificial intelligence, generative artificial intelligence, and machine learning technology (collectively, “Machine Learning Technology”) may pose risks to LPL A 1 2 – R – 1 0 2 5 P a g e 6 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE and Advisor. LPL and Advisor could be further exposed to the risks of Machine Learning Technology if third-party service providers or any counterparties, whether or not known to LPL or Advisor, also use Machine Learning Technology in their business activities. LPL and Advisor will not be in a position to control the operations of third-party service providers or counterparties, the manner in which third-party products are developed or maintained or the manner in which third-party services are provided. Machine Learning Technology is generally highly reliant on the collection and analysis of large amounts of data, and it is not possible or practicable to incorporate all relevant data into the model that Machine Learning Technology utilizes to operate. Certain data in such models will inevitably contain a degree of inaccuracy and error, potentially materially so, and could otherwise be inadequate or flawed, which would be likely to degrade the effectiveness of Machine Learning Technology. To the extent that LPL or Advisor are exposed to the risks of Machine Learning Technology, any such inaccuracies or errors could have adverse impacts on LPL or Advisor, as applicable. Machine Learning Technology and its applications, including in the financial services sector, continue to develop rapidly, and it is impossible to predict the future risks that will from time to time arise from such developments. (cid:120) Values-Based and Environmental, Social and Governance (ESG) Investing Risk. Values-based investing or ESG investing, also known as “socially responsible investing,” “sustainable investing,” or “impact investing,” focuses on the social values or environmental, social, and governance standards or the sustainability factors of an investment. Some values-based investing strategies focus on factors relating to an individual investor’s personal or religious values, such as “biblical investing,” while other strategies focus on issues like environmental impact. Some values-based investment strategies use values-based criteria to supplement financial analysis when considering a particular issuer or security, while others affirmatively select “socially responsible” investments or screen out or exclude investments in companies that engage in certain activities. Values-based investing may limit the type and number of investments available in a strategy and cause the strategy to underperform other strategies without a values-based focus or with a focus that involves a different type of focus or screening methodology. Values-based strategies may underperform the market as a whole. Companies and issuers selected in a values-based strategy may not or may not continue to demonstrate values-based characteristics. Different investors likely have different opinions about what types of investments are socially responsible. Voting Client Securities Unless a client instructs otherwise, effective November 24, 2025, LPL will vote proxies in accordance with its proxy voting policies and procedures then in effect, which will include engaging one or more third party proxy advisor vendors to make proxy voting recommendations and handle the administrative functions of voting proxies. For OMP, LPL’s proxy voting policies and procedures state that LPL will vote proxies in all instances in accordance with recommendations from Glass, Lewis & Co., a third-party proxy advisory services company, for any securities held in your account, except to the extent otherwise prohibited by law. For the avoidance of doubt, in the event that Glass, Lewis & Co. does not provide a recommendation, LPL will abstain from voting in that proxy campaign. Notwithstanding the foregoing, if Client is a plan subject to ERISA (as defined above), LPL shall vote client proxies in accordance with LPL’s obligations under ERISA and applicable Department of Labor Regulations. Client may expressly retain the right and obligation to vote any proxies or exercise any voluntary corporate actions relating to securities held in the Account, provided Client provides prior written notice to LPL. A copy of LPL’s proxy voting policies is available upon request to Advisor. A client can obtain information about how LPL voted with respect to securities held in the client’s account by contacting Advisor. If a client elects to retain the right and obligation to vote proxies and receive mutual fund shareholder reports, LPL is reimbursed by the proxy issuer or mutual fund for the delivery costs to send proxies and shareholder reports to the client. The maximum fee that can be charged for delivery is set by New York Stock Exchange (NYSE) rules. If LPL uses a vendor to perform the delivery, the vendor seeks reimbursement from the proxy issuer or mutual fund on LPL’s behalf and in certain cases remits a portion of the reimbursement to LPL. If clients have questions regarding the solicitation, they should contact the contact person that the issuer identifies in the proxy materials or their Advisor. In addition, LPL and Advisors do not accept authority to take action with respect to legal proceedings relating to securities held in the account. A 1 2 – R – 1 0 2 5 P a g e 7 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE ITEM 7 CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS The Advisor obtains the necessary financial data from the client and assists the client in setting appropriate investment objectives for the account. The Advisor obtains this information by having the client complete an Account Application which is a part of the Account Agreement. In quarterly communications, LPL asks clients to contact the Advisor if there have been any changes in the client’s financial situation or investment objectives or if they wish to impose any reasonable restrictions on the management of the account or reasonably modify existing restrictions. Clients should understand that the investment objective selected for the program in the Account Application is an overall objective for the entire account and may be inconsistent with a particular holding and the account’s performance at any time. Client also should be aware that achievement of the stated investment objective is a long-term goal for the account. ITEM 8 CLIENT CONTACT WITH PORTFOLIO MANAGERS LPL does not place any restrictions on a clients’ ability to contact and consult with Advisors. ITEM 9 ADDITIONAL INFORMATION Disciplinary Information LPL entered into a settlement with the SEC in which the SEC found that LPL willfully violated its obligations under Section 17(a) of the Exchange Act and Rule 17a-8 thereunder, which require broker-dealers to comply with certain anti-money laundering (“AML”) requirements. The SEC found that LPL did not follow its AML policies for its customer identification program and ongoing customer due diligence obligations by, among other things, not properly verifying new accounts; not timely closing accounts that did not pass its screening measures; and not closing or restricting certain accounts that were prohibited under LPL’s AML Policies. The SEC censured LPL and ordered LPL to cease and desist from committing or causing any violations and any future violations of such section and rule, to pay a civil monetary penalty in the amount of $18 million, and to comply with certain undertakings (2025). LPL entered into a settlement with the SEC in which the SEC found that LPL willfully violated Section 17(a) of the Exchange Act and Rule 17a-4(b)(4) thereunder and Section 204 of the Advisers Act and Rule 204-2(a)(7) thereunder in connection with the maintenance and preservation of off-channel communications; and failed to reasonably supervise its personnel within the meaning of Section 15(b)(4)(E) of the Exchange Act and Section 203(e)(6) of the Advisers Act. LPL admitted to the facts in the settlement order and acknowledged its conduct violated the federal securities laws. The SEC ordered LPL to cease and desist from committing or causing any violations and any future violations of Section 17(a) of the Exchange Act and Rule 17a-4(b)(4) thereunder and Section 204 of the Advisers Act and Rule 204-2(a)(7) thereunder, censured it for its conduct, ordered it to pay a civil monetary penalty in the amount of $50,000,000, and ordered it to comply with certain undertakings (2024). LPL entered into a settlement with the SEC in connection with LPL’s failure to comply with its Customer Identification Program procedures. The SEC found that LPL willfully violated Section 17(a) of the Exchange Act and Rule 17a-8 thereunder and was a cause of a third party’s violations of Sections 17(a)(2) and (3) of the Securities Act and Section 206(2) of the Advisers Act. The SEC ordered LPL to cease and desist from committing or causing any further violations of these laws and regulations, censured LPL for its conduct, and ordered the payment of disgorgement and prejudgment interest totaling $141,202 (deemed satisfied based on LPL’s voluntary remedial payment of $4,118,876 to the impacted client), and the payment of a civil money penalty of $750,000 (2021). As part of a voluntary self-reporting initiative in 2019, LPL entered into a settlement with the SEC in which the SEC found that LPL willfully violated Section 206(2) and 207 of the Investment Advisers Act of 1940 (the “Advisers Act”) in connection with inadequate disclosure to clients of its and its associated persons’ conflicts of interest related to its receipt of 12b-1 fees and/or its selection of mutual fund share classes that pay such fees. The SEC ordered LPL to cease and desist from committing or causing any violations of Sections 206(2) and 207 of the Advisers Act, censured it for its conduct, and ordered the payment of disgorgement and prejudgment interest to affected investors totaling $9,333,516 (2019). LPL, as a broker-dealer, is a member of (“FINRA”) and has found to be in violation of FINRA’s rules related to its brokerage activities. In particular, LPL consented to sanctions related to the following matters: A 1 2 – R – 1 0 2 5 P a g e 8 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE (cid:120) (cid:120) (cid:120) (cid:120) (cid:120) (cid:120) (cid:120) (cid:120) (cid:120) (cid:120) LPL’s supervisory systems and maintenance of books and records relating to brokerage direct business transactions, supervisory systems and misstatements about fees relating to brokerage product switch transactions, and supervisory systems relating to brokerage recommendations of publicly traded securities of business development companies (BDCs) to customers, resulting in a censure, a fine of $5.5 million, restitution to impacted customers, and an undertaking to certify that LPL has remediated the systems and procedures for making recommendations of BDCs (2023). LPL’s supervisory systems and procedures relating to the transmittal of customer funds by wire or check to third parties and maintenance of related books and records, resulting in a censure, a fine of $3,000,000, restitution to impacted clients, and an undertaking to identify and pay restitution to affected customers for certain other improper transfers (2023). LPL’s failure to accurately calculate its customer reserve requirement, failure to maintain a sufficient customer reserve, failure to maintain policies and procedures reasonably designed to achieve compliance with the Securities and Exchange Act and FINRA rules, and failure to maintain accurate books and records, resulting in a censure and a fine of $300,000 (2022). LPL’s self-reporting of potential issues related to certain C-share purchase suitability reviews and its supervisory systems and procedures relating to waivers of front-end sales charges for rollovers of 529 savings plan investments from one state plan to another, resulting in a censure and payment of restitution to impacted customers (2021). LPL’s supervisory systems and procedures relating to record retention, fingerprinting and screening of certain associated persons, and supervision of consolidated reports, resulting in a censure, a fine of $6,500,000 and an undertaking to review and enhance related policies, systems and procedures (2020). LPL’s supervisory systems and procedures relating to changes in the authority of custodians of accounts established under the Uniform Gifts to Minors Act and/or the Uniform Transfers to Minors Act, resulting in a censure, a fine of $300,000, and an undertaking to review and enhance its policies, systems, and procedures related to supervision of such accounts (2019). (cid:120) The effectiveness of LPL’s anti-money laundering program, LPL’s failure to amend certain Forms U4 and U5, and LPL’s systems and supervisory procedures relating to Forms U4 and U5 reporting requirements, resulting in a censure and a fine of $2,750,000 and an undertaking to review the process used to disclose customer complaints on Forms U4 and U5 (2018). LPL’s brokerage supervisory and disclosure procedures related to the sale of certain brokered certificates of deposit in brokerage accounts, resulting in a censure and a fine of $375,000 (2018). LPL’s systems and supervisory procedures relating to the creation and distribution of certain required account notices, resulting in a censure, a fine of $900,000, and an undertaking to review affected processes (2016). LPL’s systems and supervisory procedures relating to the format in which certain electronic records were retained, resulting in a censure and a fine of $750,000 (2016). LPL’s various brokerage supervisory procedures, including those related to the sale of complex non-traditional ETFs, variable annuity (“VA”) contracts, real estate investment trusts (“REITs”) and other products in brokerage accounts, as well as LPL’s failure to monitor and report trades and deliver trade confirmations, resulting in a censure and a fine of $10,000,000, and restitution of $1,664,592 (2015). LPL, as a broker-dealer, is regulated by each of the 50 states and has been the subject of orders related to the violation of state laws and regulations in connection with its brokerage activities. In particular, LPL entered into consent orders related to the following matters: (cid:120) (cid:120) (cid:120) LPL’s supervision of electronic signature practices at an LPL branch office in Massachusetts, resulting in a fine of $250,000 and an undertaking to conduct an internal review of certain related policies and procedures (Massachusetts or “MA”, 2023). LPL’s supervision of an LPL broker-dealer/investment adviser agent’s sales of structured products, resulting in a censure, an offer of restitution to impacted clients, and a fine of $125,000 (Texas, 2022). LPL’s supervision of two LPL broker-dealer and/or investment adviser agents who pled guilty to charges of fraudulent practices with LPL customers, resulting in a cease and desist order, a fine of $350,000 and a $150,000 contribution for financial literacy and investor education initiatives, training and related materials (Connecticut, 2021). A 1 2 – R – 1 0 2 5 P a g e 9 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE (cid:120) (cid:120) (cid:120) LPL’s supervision of an LPL representative under a heightened supervision plan, resulting in a cease and desist order; a fine of $275,000; payments of restitution, disgorgement and investigative costs; and offers of payment of surrender charges in connection with variable annuity contracts for impacted customers (New Hampshire or “NH”, 2020). LPL’s failure to timely register (or maintain the registration of) certain agents in MA and failure to amend Forms U4 and U5 for certain agents registered in MA, resulting in a censure, a fine of $1,100,000, and an undertaking to review and enhance its policies and procedures related to registering its agents in MA and filing reportable events (MA, 2019). LPL’s brokerage supervisory procedures relating to email review and annual branch office examinations, resulting in a civil penalty of $450,000 and an undertaking for third-party review of related processes (Indiana, 2018). (cid:120) The sale of unregistered, non-exempt securities in violation of state registration requirements, resulting (upon entry of the individual consent order) in payment to each participating state or jurisdiction of a civil penalty of $499,000, reimbursement of certain investigative expenses, remediation through repurchase of certain securities and payment of losses to certain affected customers, and certain additional undertakings (Settlement with up to 53 members of the North American Securities Administrators Association (NASAA), 2018). (cid:120) (cid:120) (cid:120) The sale of non-traded alternative investments in excess of prospectus standards or LPL’s internal guidelines and the maintenance of related books and records, resulting in a censure, a fine of $950,000, a $25,000 contribution to an investor education fund and remediation of losses to impacted customers (New Jersey, 2017). LPL’s supervisory practices for LPL representatives located on the premises of a credit union, resulting in a censure, a fine of $1,000,000, and an undertaking to avoid investor confusion specific to the name under which the credit union does business and review LPL’s related policies and procedures (MA, 2017). LPL’s oversight of certain VA transactions, resulting in a censure, a fine of $975,000, restitution to clients and former clients of an LPL representative, disgorgement of commissions retained by LPL in connection with such representative’s VA sales, and an undertaking to review such representative’s brokerage and advisory activities and LPL’s related policies and procedures (MA, 2017). (cid:120) The sale in brokerage accounts of non-traded REITs in excess of prospectus standards, state concentration limits or LPL’s internal guidelines, resulting in an aggregate civil penalty of $1,425,000, reimbursement of certain investigative expenses and remediation of losses to impacted customers (Global settlement with certain members of NASAA, 2015). (cid:120) The sale of non-traded REITs in excess of prospectus standards, state concentration limits or LPL’s internal guidelines, resulting in an administrative fine of $250,000, reimbursement of investigative costs of $250,000, a $250,000 contribution to an investor education fund and remediation of losses to impacted customers (NH, 2015). (cid:120) The sale of leveraged and inverse leveraged ETFs (“Leveraged ETFs”), resulting in an administrative fine of $50,000 (Delaware), a penalty of $200,000 (MA), restitution to Delaware customers in an amount up to $150,000, restitution to MA customers in an amount up to $1,600,000, and an agreement to make certain changes in its supervisory system with respect to Leveraged ETFs (2015). (cid:120) Failure to implement procedures related to the use of senior-specific titles by LPL representatives as required under MA law, resulting in a censure and a fine of $250,000 (2015). For more information about those state events and other disciplinary and legal events involving LPL, client should refer to Investment Adviser Public Disclosure at https://adviserinfo.sec.gov/ or FINRA BrokerCheck at https://brokercheck.finra.org/ Other Financial Industry Activities and Affiliations LPL is a broker-dealer registered with FINRA and the SEC. As a broker-dealer, LPL transacts business in various types of securities, including mutual funds, stocks, bonds, commodities, options, private and public partnerships, variable annuities, REITs and other investment products. LPL is registered to operate in all 50 states and has primarily an independent-contractor sales force of registered representatives and investment adviser representatives dispersed throughout the U.S. LPL has a dedicated team of employee IARs in its offices who service certain accounts, and also a small subset of IARs who operate their own offices or are located on the premises of certain financial institutions and are employees of LPL Employee Services, LLC, an LPL-affiliated company. LPL is also registered as an introducing broker with the Commodity Futures Trading Commission. In addition, LPL is qualified to sell insurance products in all 50 states. A 1 2 – R – 1 0 2 5 P a g e 1 0 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE Associated persons of Advisor may also be broker-dealer registered representatives of LPL or another broker-dealer. If an associated person of Advisor is a broker-dealer registered representative of LPL, that person is providing advisory services to the program account on behalf of Advisor. That person is not acting in a broker-dealer capacity or on behalf of LPL with respect to the services provided under the program. LPL also contracts with other advisors to make the program available to clients through the other advisor firms. In such case, LPL and the other advisor firms share in the Account Fee. LPL Enterprise, LLC (“LPLE”), is a registered broker-dealer and related person of LPL. LPLE became a registered investment adviser in August Our affiliate, LPLE, is an investment adviser registered with the SEC and a broker-dealer registered with FINRA and the SEC. As a broker-dealer, LPLE transacts business in various types of securities, including mutual funds, stocks, bonds, commodities, options, private and public partnerships, variable annuities, REITs and other investment products. LPLE is registered to operate in all 50 states and has primarily an independent-contractor sales force of registered representatives and investment advisor representatives dispersed throughout the United States. If required for their positions with a registered broker-dealer, LPLE’s principal executive officers are securities licensed as registered representatives of LPL. In addition, LPLE is qualified to sell insurance products in all 50 states. LPL and The Private Trust Company, N.A. (“PTC”), a federally chartered non-depository bank licensed to provide trust services in all 50 states, are related persons. PTC serves as IRA custodian for program accounts set up as IRAs and receives an annual maintenance fee for this service. PTC also provides personal trustee services to clients for a variety of administrative fiduciary services, which services may relate to a program account. Because LPL and PTC are affiliated companies and share in revenues, there is a financial benefit to the companies if a client uses PTC as a custodian or for personal trustee services, or if a PTC client uses LPL as an investment adviser. PTC’s IRA custodian and trustee services and related fees are established under a separate engagement between the client and PTC. Fiduciary Trust Company of New Hampshire (“FTC”), a non-depository trust company, is a related person of LPL. FTC provides custodial and various other recordkeeping and services to IRAs and certain employer-sponsored plans maintained through non- OMP program accounts. Because LPL and FTC are affiliated companies and share in revenues, there is a financial benefit to the companies if a client is referred to or otherwise elects to engage with FTC for services under another LPL program, and uses LPL as the investment adviser or broker-dealer. FTC’s custodial and recordkeeping services and related fees are established under a separate engagement between the client and FTC. Code of Ethics and Personal Trading LPL has adopted a code of ethics that includes guidelines regarding personal securities transactions of its employees and investment advisor representatives (“IARs”). The code of ethics permits LPL employees and LPL IARs to invest for their own personal accounts in the same securities that LPL and IARs purchase for clients in program accounts. This presents a conflict of interest because trading by an employee or IAR in a personal securities account in the same security on or about the same time as trading by a client can disadvantage the client. LPL requires in its code of ethics that LPL employees and LPL IARs report certain personal securities transactions and holdings to LPL. LPL generally has procedures to review personal trading accounts for front-running. However, since LPL’s Research Department has sole control over trading decisions (including timing of implementation thereof) for the Model Portfolios in the Program, the potential for front-running by most LPL employees and LPL IARs is limited, and no such review is conducted other than for employees in LPL’s Research Department. In addition, employees in LPL’s Research Department are required to obtain pre-clearance prior to purchasing certain securities for a personal account. Employees and IARs are also required to obtain pre-approval for investments in private placements and initial public offerings. A copy of the LPL code of ethics is available to clients or prospective clients upon request and is available at lpl.com/disclosures.html. Participation or Interest in Client Transactions Purchases of mutual fund shares may be processed through LPL’s proprietary account resulting in such purchases being characterized as principal transactions for certain reporting purposes. In such case, the shares will be purchased at the fund’s net asset value, and no additional charges will be applied to such transactions as a result of LPL’s use of a proprietary account. A 1 2 – R – 1 0 2 5 P a g e 1 1 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE LPL does not otherwise engage in principal transactions with its clients in the program. LPL’s parent company, LPL Financial Holdings Inc., is a publicly traded company. LPL Financial Holdings Inc. stock may not be purchased directly in OMP accounts. However, an OMP account may include a mutual fund that holds LPL Financial Holdings Inc. stock as an underlying investment. LPL provides investment consulting services to the investment advisor of the Optimum Funds. These services include assisting the investment advisor in determining whether to engage, maintain or terminate sub-advisors for the Optimum Funds. As compensation for these services, LPL receives an investment consulting fee of up to 0.22% of assets from the investment advisor to the Optimum Funds. In addition, a senior executive officer of LPL serves as a Trustee of the Optimum Funds. Certain of the Optimum Funds are subject to voluntary expense caps that may result in the adviser to the Optimum Funds waiving fees or reimbursing expenses that exceed those caps. The adviser to the Optimum Funds bears the cost of any reimbursements or waivers. LPL also performs recordkeeping, administrative and shareholder services on behalf of the Optimum Funds and receives compensation for the services based on the amount of Program assets that are invested in the funds (up to 0.15% annually). These services include establishing and maintaining accounts with the Optimum Funds, facilitating settlement of funds, responding to customer inquiries and requests, and maintaining sub-account records reflecting the issuance, exchange or redemption of shares by each program account. The receipt of this recordkeeping and investment consulting compensation by LPL is an important revenue stream and presents a conflict of interest, because LPL has a financial benefit the more assets that are invested in the Optimum Funds. The investment consulting and recordkeeping compensation is retained by LPL and is not shared with Advisors. Although LPL does not share investment consulting and recordkeeping compensation with Advisors or IARs, such fees and payments will increase LPL’s profits and indirectly benefit Advisors, for example by being used by LPL to support marketing or training costs. In addition, LPL charges a setup fee to product sponsors when adding new investment products or share classes of an investment product to LPL’s investment platforms. In the case of exchange traded products, LPL receives up to $15,000 as a sponsor level due diligence fee, up to $7,500 per fund and up to an additional $15,000 per product for complex ETPs and ETPs. In the case of mutual funds, LPL receives a one-time set up fee of up to $15,000 as a sponsor level due diligence fee and a setup fee of $7,500 per fund. In the case of UITs, LPL charges up to $5,000 per trust. LPL does not share this compensation with Advisor or its IARs. LPL offers product sponsors of mutual funds, closed funds, interval funds, ETFs, alternative investments, advisory strategies, annuities and life insurance contracts the opportunity to purchase analytical data, business intelligence and ad hoc reporting. This information helps product sponsors in their sales, distribution and product development efforts with respect to customers and clients and creates similar conflicts to those discussed above. LPL receives up to $600,000 annually from each product sponsor in third party compensation for this information. Cash Sweep Service Options LPL automatically transfers cash balances (including otherwise uninvested cash amounts received from the customer, securities transactions, dividend and interest payments, and other account-related activities) in a customer’s eligible accounts through the account’s designated sweep service option, where applicable. The type of sweep service options available (and how cash is held) depends on the customer’s account type. LPL offers Federal Deposit Insurance Corporation (“FDIC”)-insured bank sweep services for most customer accounts. Accounts may be eligible for the LPL Insured Cash Account (“ICA”) Program, the LPL Deposit Cash Account (“DCA”) Program or the money market mutual fund sweep, each described below. Not all sweep service options are available to all types of customer accounts. Cash sweep is offered as an account feature and service to facilitate the operation and maintenance of the account and is not intended to be used as an investment option or as part of an account’s asset allocation, though for certain advisory accounts, it is typical for an account to have an allocation to cash to support the operational needs and fees charged to the account. LPL and its financial professionals do not typically recommend specific sweep service options or underlying sweep holdings. For more information, please see your customer agreement and the applicable ICA or DCA disclosure booklet, or the sweep money market fund prospectus. A 1 2 – R – 1 0 2 5 P a g e 1 2 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE The aggregate fees and expenses received by LPL in connection with the customer account’s designated sweep service option can be higher or lower than the customer’s yields on the sweep service option depending on the particular sweep option, prevailing interest rates and other market factors. See https://www.lpl.com/disclosures/lpl-financial-fdic-insured-bank-deposit- sweep-programs.html for Information about our customer fees and customer Interest rates for ICA and DCA, or contact your financial professional for information about our customer fees and customer interest rates for money market funds. Historically, customer yields in ICA have always been lower than the aggregate fees and charges received by LPL. Customer yields in DCA and in money market mutual funds have been both lower and higher than the aggregate fees and charges received by LPL. Cash sweep services are not intended to be used for long-term investments and are more appropriately viewed as an indirect cost of maintaining and operating the account. LPL makes available a wide range of investment alternatives with differing risk and return characteristics, which are better suited for meeting customer investment needs and objectives. Customers should compare the terms, interest rates, required minimum amounts and other features of their account’s applicable sweep service option available through other types of accounts and investment options available in their account. FDIC insurance protects against the loss of FDIC-insured deposits if the depository institution or bank holding the deposit fails. LPL itself is not an FDIC-insured depository institution. With respect to our sweep service options, only balances received by, and deposited at, the ICA and DCA are eligible for FDIC insurance (subject to applicable limits). Eligibility for pass-through deposit insurance coverage for ICA and DCA, deposits is subject to fulfilling specific conditions. Client Cash Accounts and money market mutual funds are not customer bank deposits and are subject to investment risks, including the potential loss of the amount invested. These investments are not FDIC-Insured, but may be subject to SIPC protection. (cid:120) Insured Cash Account (ICA). LPL's ICA sweep service option automatically sweeps otherwise uninvested cash balances held within customer brokerage (and certain advisory accounts) into interest-bearing bank deposits eligible for FDIC insurance (subject to applicable limits). Under its agreement with each ICA participating bank in which customer cash may be swept, LPL receives a fee from the bank equal to a percentage of the average daily deposit balance held at the bank. Such fees differ among the participating banks depending on the current interest rate environment and/or any fee waivers made by LPL. The fee LPL receives is generally an average aggregate annual rate of up to 6% as applied across the deposits held at all of the ICA participating banks. Because the banks generally pay different amounts to LPL on account balances, fees received by LPL with respect to a specific customer account (and the account's cash holdings) may be higher or lower than this average percentage amount. The fees received by LPL from the ICA participating banks reduce the interest rate customers receive on their cash held through ICA. These fees are additional compensation to LPL for operating and maintaining the account and for LPL’s other services to the account. LPL has chosen to offer ICA as the sole sweep service option for certain account types, in part because of the additional compensation LPL earns from the use of ICA. In situations where customer cash balances allocated through ICA exceed the deposit availability at ICA participating banks, uninsured cash balances may be placed into an “overflow” Client Cash Account. Such balances are considered to be “free credit balances” and represent a direct liability of LPL to the customer. See below for information about how LPL is compensated on Client Cash Account balances. (cid:120) Deposit Cash Account (DCA). LPL's DCA sweep service option automatically sweeps otherwise uninvested cash balances held within certain advisory accounts into interest bearing bank deposits eligible for FDIC Insurance (subject to applicable limits). In the DCA program, each Bank pays compensation equal to a percentage of the average daily aggregated omnibus deposit balance held at the bank. This amount includes the fee for the third-party administrator, LPL’s per account fee, and interest payable to participating accounts. Such fees differ among the participating banks. Customers have no rights to the amounts paid by the DCA participating banks, except for interest actually credited to the customer account. However, amounts collected from the DCA participating banks during each period, less interest credited, will be allocated on a per-dollar, per-account basis and used to offset each customer’s monthly LPL account fee for providing the sweep services. In addition, part of the payment by the participating banks will be used to compensate the third-party administrator for its services. For its services under the DCA program, including making the platform available, LPL receives a per-account fee each month. The monthly fee is based on a fee schedule indexed to A 1 2 – R – 1 0 2 5 P a g e 1 3 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE the current Federal Funds Target (FFT) Rate as detailed in the DCA Disclosure Booklet located on lpl.com. The current fee can also be found at lpl.com. It is expected that this fee will be recouped from the DCA participating banks and will not be a fee directly applied to customer accounts. The fee LPL receives under the DCA program does not vary, and is not affected by the actual amounts held in the deposit accounts or in the customer’s account. LPL has chosen to offer DCA as the sole service option for certain account types, in part because of the additional compensation LPL earns from the use of DCA. In situations where customer cash balances in DCA exceed the deposit availability at DCA participating banks, uninsured cash balances may be placed into an “overflow” money market mutual fund. See below for further information about fees generated by cash balances maintained in the DCA “overflow” money market mutual fund. (cid:120) Client Cash Accounts – ICA Overflow Balances. LPL receives additional compensation and benefits from the customer cash balances maintained in the ICA overflow mechanism, referred to as Client Cash Account, which constitute free credit balances available for LPL use. LPL can use free credit balances to fund its ongoing operations subject to the limitations under SEC Rule 15c3-3. Pursuant to Rule 15c3-3, LPL can (i) deposit free credit cash balances into a segregated deposit account at its banks, thereby earning interest on the Client Cash Account balances deposited, or (ii) invest the cash balances in securities backed by the full faith and credit of the U.S. government, thereby making money on any yield generated by such securities. The amount LPL will earn from these sources will vary based on market forces and the contracts for deposit arrangements that LPL is able to secure with its banks. LPL may use both or either of these vehicles at its sole discretion. Any amounts LPL receives pursuant to these sources will be reduced by the interest payable, if any, to customers on such balances, and further reduced by the cost of borrowing any funds necessary to meet its reserve requirements under Rule 15c3-3. For example, LPL may earn interest or a return by investing in short- term U.S. Government or Agency instruments or by using these balances to fund margin loans to its customers at a lower funding cost than would otherwise be the case. Customers do not share in the returns or proceeds associated with LPL's use or investment of such free credit balances, which are expected to exceed the amount of any Interest paid to the customer for Client Cash Account balances. (cid:120) Money Market Mutual Fund Sweep Option. For customer accounts not eligible for ICA or DCA, otherwise uninvested cash balances held in the account are automatically swept and invested daily into shares of a money market mutual fund. Currently, taxable and tax-exempt money market funds offered by J.P. Morgan Asset Management and Federated Services Company, are available. LPL receives compensation in the form of servicing fees of up to 0.25% of customer assets invested in J.P. Morgan Asset Management money market funds and up to 0.35% of customer assets invested in Federated Services Company money market funds. These money market mutual funds generally pay higher 12b-1 fees than other money market funds that are not used for sweep services. The 12b-1 fees and the payer of such fees are set out in the prospectus of the money market mutual fund. LPL receives service and administrative fees relating to the support of the sweep program from the sponsors of these funds, ranging between 0.25% and 0.45% of the assets Invested In the money market funds. Such fees may be waived by the fund companies in their sole discretion. These payments are in addition to other fees (e.g., recordkeeping and 12b-1 fees) received by LPL, where applicable. LPL also receives fees of up to 0.45% for DCA “overflow” balances that are swept into the Goldman Sachs Asset Management Financial Square Government Fund, if any. The fees and the payer of such fees are set out in the prospectus of the money market fund. The compensation that LPL receives related to ICA, DCA (including from any ICA and DCA overflow mechanisms) and the Sweep Funds is in addition to the Account Fee received with respect to the assets in the sweep investment. This compensation related to ICA, DCA and Sweep Funds is an important revenue stream and presents a conflict of interest to LPL because LPL has a financial benefit if cash balances are maintained in the ICA, DCA or Sweep Fund. However, the compensation LPL receives on ICA, and DCA and Sweep Funds is retained by LPL and is not shared with Advisors. In addition, LPL Research does not take into account this compensation when it makes decisions on a Portfolio’s allocation to cash. A 1 2 – R – 1 0 2 5 P a g e 1 4 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE Collateralized Lending Arrangements LPL has partnered with certain banks to help facilitate clients’ access to non-purpose lines of credit collateralized by their investment accounts. Because of LPL’s arrangements with the banks participating in the program, clients may be limited in their ability to negotiate the most favorable loan terms. Clients are not required to use the banks in LPL’s program, and can work directly with other banks to negotiate loan terms or obtain other, potentially more favorable, financing arrangements. If a Client obtains a loan from a non-partner bank, he should notify Advisor of the amount of the line of credit. Clients should understand that the interest and additional fees paid to the bank in connection with the loan are separate from and in addition to the advisory fees the client pays LPL for its advisory services on the account. LPL receives third party compensation from participant banks based on the amount of outstanding loans. Compensation can be up to 0.75% of the outstanding loan amount. This compensation to LPL varies, and, therefore, LPL can earn more or less depending on the bank selected by the client. The receipt of compensation poses a conflict of interest to LPL because LPL has a financial incentive for the client to select a bank in the program, as well as a participating bank that pays LPL more than other participating banks. However, LPL does not share this compensation with Advisor, and therefore, Advisor does not have a financial incentive if one bank is selected over another. LPL and Advisor have an interest in continuing to receive investment advisory fees, which gives LPL and Advisor an incentive to recommend that clients borrow money rather than liquidate some of their assets managed by LPL and Advisor. This incentive creates a conflict of interest for LPL and Advisor when advising clients seeking to access funds on whether they should liquidate assets or instead hold their securities investments and utilize a line of credit secured by assets in their account. Because LPL and Advisor are compensated primarily through advisory fees paid on clients’ accounts, LPL and Advisor also have an interest in managing an account serving as collateral for a loan in a manner that will preserve sufficient collateral value to support the loan and avoid a bank call. This may present a conflict of interest with clients because it could incentivize Advisor to invest in more conservative, lower performing investments to maintain the stability of the account. For additional information regarding LPL’s collateralized lending program, including a list of the banks currently participating in the program, please visit lpl.com/disclosures.html, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Third Party Compensation and Related Conflicts of Interest.” Credit Cards As part of its cash management services, LPL makes available for its customers credit cards through a partner bank. LPL receives a flat fee for each new activated credit card that is used by the cardholder in the first 90 days. LPL also receives a portion of the transaction volume of the cardholder’s account. LPL’s portion of the transaction volume varies depending on the number of LPL active cardholder accounts. Other Clients Client should understand that LPL and Advisor perform advisory and/or brokerage services for various other clients, and that LPL and Advisor may give advice or take actions for those other clients that differ from the advice given to the client. The timing and nature of any action taken for the account may also be different. Review of Accounts LPL provides Advisor and/or clients with regular written reports and statements regarding their accounts. LPL provides Advisor, and clients, if so directed by Advisor, annual performance information describing account performance and positions. In addition, LPL transmits to clients account statements showing transactions, positions, and deposits and withdrawals of principal and income. Portfolio values and returns shown in performance reports for the year-end time period may include mutual fund dividends paid out prior to December 31 but that were posted to the account within the first 2 business days of the subsequent year. The inclusion of such dividends in the year-end performance report may cause discrepancies between the report and the account statement client receives from LPL for the same period. A 1 2 – R – 1 0 2 5 P a g e 1 5 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE Other Compensation LPL and LPL employees receive additional compensation, business entertainment and gifts from product sponsors. Such compensation may not be tied to the sales of any products or services. Compensation includes such items as gifts valued at less than $100 annually, an occasional dinner or ticket to a sporting event, or reimbursement in connection with educational meetings, customer appreciation events or marketing or advertising initiatives. Product sponsors may also pay for, or reimburse LPL for the costs associated with, education or training events that may be attended by LPL employees and representatives and Advisor and its employees and representatives and for LPL-sponsored conferences and events. LPL and LPL employees also receive reimbursement from product sponsors for technology-related costs, such as those to build systems, tools and new features to aid in serving customers. LPL receives compensation in the form of earnings on its short-term investment of cash in program accounts prior to the time the cash is invested for the account. These earnings are generally known as "float." Cash in the account would typically result from contributions to the account or sales of securities in the account. For accounts that opt out of the sweep program, the accounts may remain in free credit balances. In such case, LPL receives compensation in the form of earnings on cash. LPL does not share this compensation with Advisor. LPL employees provide sales support resources to Advisor that use LPL advisory programs. The compensation that LPL pays to these employees varies based on the assets in LPL’s different advisory programs. These employees have an incentive to promote OMP to Advisor over other advisory programs. These employees also earn more compensation when Advisor transitions client assets from brokerage accounts to advisory accounts, and have a financial incentive to encourage Advisor to transition brokerage accounts to advisory. In the event a trade error occurs in the Account, and such error is determined to be caused by LPL, LPL typically will cancel the trade and remove the resulting monetary loss to the client from the account. If a trade correction is required as a result of client (e.g., if client does not make full payment for purchases or fails to deliver negotiable securities for liquidations before trade settlement), LPL typically will cancel the trade and any resulting monetary loss will be borne by the client. In the case of a trade that requires a correction as described above and that resulted in a monetary gain to the client, such gain will be removed from the account and can result in a financial benefit to LPL. Conflicts Related to LPL Compensation to Advisor LPL pays compensation to Advisor, which includes a portion of the Account Fee and also may include other compensation, such as bonuses, awards or other things of value offered by LPL to the Advisor and/or its representatives. Individuals of Advisor also may be associated with LPL as broker-dealer registered representatives and/or investment advisor representatives. In particular, LPL pays additional compensation to Advisor or its representatives by providing, for example: payments based on production (cid:120) (cid:120) (cid:120) equity awards from LPL’s parent company, LPL Financial Holdings Inc., consisting of awards of either restricted stock units (a promise to deliver stock in the future) or stock options to purchase stock, in each case subject to satisfaction of vesting and other conditions reimbursement or credits of fees that Advisor and/or its IARs pay to LPL for items such as administrative services, or technology fees free or reduced-cost marketing materials advances of advisory fees (cid:120) (cid:120) payments in connection with the transition of Advisor’s business from another firm to LPL (cid:120) (cid:120) payments in the form of repayable or forgivable loans (cid:120) attendance at LPL conferences and events. Some of these forms of compensation, particularly equity awards of LPL Financial Holdings Inc., give Advisor a financial interest in the success of LPL. If Advisor has a financial interest in the success of LPL, Advisor has an incentive to recommend investments that are more profitable for LPL, regardless of whether Advisor shares in that compensation directly. A 1 2 – R – 1 0 2 5 P a g e 1 6 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE Advisor has a financial incentive to negotiate fee arrangements that maximize its compensation. In some programs, Advisor charges a negotiable advisory fee for itself plus a fee for third-party managers that is not negotiable. Differences in fees for third-party managers, and the absence of such fees in other programs, creates a conflict of interest for Advisor insofar as Advisor can negotiate a higher advisory fee for a program or strategy with lower or no separate manager fee than they could for an account subject to a higher third-party manager. The amount received by Advisor as a result of a client’s participation in any particular program offered by LPL often is more than Advisor would have received if the client participated in other programs, paid third-party manager fees, or paid separately for investment advice, brokerage and other services covered by the account fee. LPL also charges Advisor various fees under its master services agreement, for example, for administrative, custody and clearing services to accounts, technology and licensing. In certain cases, LPL pays Advisor this compensation, and charges Advisor these fees, based on Advisor’s overall business production and/or on the amount of assets serviced in LPL advisory relationships. When compensation or fees charged is based on the level of production or advisory assets of Advisor, Advisor has a financial incentive to meet those production or asset levels. The amount of this compensation from LPL could be more, and the amount of these fees charged by LPL could be less, than what Advisor would receive, or pay, if he or she associated with another financial services firm. The level of compensation and costs is an incentive for Advisor to become associated with LPL over another financial services firm. This compensation Advisor receives from LPL could be more than if the client participated in other LPL programs, programs of other investment advisors or paid separately for investment advice, brokerage and other client services, and likewise, the fees that Advisor pays to LPL could be less for OMP than other programs or services. In such cases, Advisor has a financial incentive to recommend advisory services in OMP over other programs and services. Although Advisor may factor in the fees charged to them by LPL in the overall Advisory Fee negotiated by the client, Advisor can still earn more for offering OMP at a lower overall fee rate than the fee rate for a program offering a third-party manager. However, Advisor may only recommend a program or service that it believes is suitable and in the best interests of a client in accordance with the applicable standards under the Advisers Act or other applicable law. LPL also provides various benefits and/or payments to third party investment advisor firms with broker-dealer registered representatives that are newly associated with LPL to assist the firm with the costs (including foregone revenues during account transition) associated with transitioning its business to LPL (collectively referred to as “Transition Assistance”). The proceeds of such Transition Assistance payments are intended to be used for a variety of purposes, including but not necessarily limited to, providing working capital to assist in funding the firm’s business, satisfying any outstanding debt owed to its prior affiliated firm, offsetting account transfer fees (ACATs) as a result of the firm’s clients transitioning to LPL’s custodial platform, technology set- up fees, marketing and mailing costs, stationary and licensure transfer fees, moving expenses, office space expenses, staffing support and termination fees associated with moving accounts. The amount of the Transition Assistance payments are often significant in relation to the overall revenue earned or compensation received by the firm at its prior affiliated firm. Such payments are generally based on the size of the firm’s business established at its prior affiliated firm, for example, a percentage of the revenue earned or eligible assets serviced at its prior affiliated firm and, in certain cases, on the amount of the investment adviser firm’s client assets that are transferred to LPL above an agreed-upon threshold. These payments are generally in the form of payments or loans to the investment adviser firm with favorable interest rate terms as permitted under applicable law, which are paid by LPL or forgiven by LPL based on years of service with LPL (e.g., if the firm remains with LPL for 5 years) and/or the scope of business engaged in with LPL. LPL does not verify that any payments made are actually used for such transition costs. Clients should refer to the third party investment advisor firm’s Form ADV brochure for more information about conflicts of interest. The receipt of Transition Assistance creates a conflict of interest in that a firm has a financial incentive to recommend that a client open and maintain an account with the firm and LPL for advisory, brokerage and/or custody services, and to recommend switching investment products or services where a client’s current investment options are not available through LPL, in order to receive the Transition Assistance benefit or payment. LPL attempts to mitigate these conflicts of interest by evaluating and recommending that clients use LPL’s services based on the benefits that such services provide to clients, rather than the A 1 2 – R – 1 0 2 5 P a g e 1 7 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE Transition Assistance earned by any particular firm. However, clients should be aware of this conflict and take it into consideration in making a decision whether to establish or maintain a relationship with LPL. LPL Interests in Investment Advisers As part of its business initiatives, LPL acquires or may take a financial interest in third-party investment advisers (“RIA Firms”) that utilize LPL as their custodian. These RIA Firms offer LPL’s investment advisory programs to their clients, and LPL earns compensation as a result of their use of its programs. When LPL acquires an RIA Firm and integrates that RIA Firm into LPL’s investment adviser, it registers the investment adviser representatives (“IARs”) with it and they (and any other staff retained or engaged by LPL) become subject to LPL’s code of ethics and have new and different conflicts of interest when recommending investment advisory products to clients. The IARs may brand their financial services practice under the RIA Firm’s prior name (Doing-Business-As or “DBA” name), but they will be offering all advisory services through LPL. Alternatively, LPL may acquire the RIA Firm and continue operating it as a going concern. There, the IARs remain IARs of the RIA Firm, and LPL amends its regulatory records to reflect the RIA Firm as an affiliate. In the event LPL takes a limited financial interest in an RIA Firm, the terms of the ownership interest will dictate LPL’s share of the RIA Firm’s advisory revenue and other sources of income. In all cases, LPL has a financial interest in the success of the RIA Firm. IARs of LPL have access to different products and services than LPL makes available to the financial professionals of third-party RIA Firms. Clients should ask their financial professional about the extent to which LPL has a financial interest in their practice. Financial Information and Custody LPL is a qualified custodian as defined in Rule 206(4)-2 under the Advisers Act and maintains custody of OMP client funds and securities in a separate account for each client under the client’s name. LPL as a qualified custodian sends account statements showing all transactions, positions, and all deposits and withdrawals of principal and income. LPL sends account statements periodically when the account has had activity or quarterly if there has been no activity. Clients should carefully review those account statements. Brokerage Practices In OMP, LPL requires that clients direct LPL as the sole and exclusive broker-dealer to execute transactions in the account. Clients should understand that not all advisors or program sponsors require their clients to direct brokerage. However, clients should understand that LPL is not paid a commission or transaction charge for executing transactions in OMP accounts and execution is made at the net asset value of the mutual fund. Although LPL is not paid a commission or transaction charge for transactions in the account, LPL bears costs for each transaction made in an account. This presents a conflict of interest because these costs may be a factor LPL considers when deciding which securities to select and whether or not to place transactions in an account. However, LPL mitigates this conflict by compensating the team responsible for directing the trades through a bonus based on the performance of the portfolios; therefore, the team is not incentivized by cost reduction. LPL will aggregate transactions for a client with other clients. LPL also will aggregate rebalancing transactions for an account with other program accounts. Due to the large number of accounts that may be involved in rebalancing transactions on a single day, LPL may effect transactions for some accounts on one day and for other accounts on the following day or days. In such case, LPL will have discretion to sequence the accounts involved in rebalancing transactions with the goal of treating all accounts equitably over time. LPL will reinvest dividends in accordance with LPL’s Dividend Reinvestment Program (“DRP”). Some securities held in the Account may be ineligible for DRP, including securities not custodied at LPL Financial. There is no requirement to participate in the DRP, Client can enroll or unenroll at any time by contacting their Advisor or LPL. DRP transactions will be confirmed on at least a quarterly basis as part of the regular periodic account statement. Additional important disclosures about DRP, including eligibility, fees, how dividends are reinvested, and more can be found at lpl.com/disclosures.html. Certain orders may be blocked or subject to review by LPL before they are directed to an exchange or market maker for execution. This review may result in a delay in execution. LPL reserves the right to place restrictions on your account in our sole A 1 2 – R – 1 0 2 5 P a g e 1 8 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE discretion, and to cancel any order that we believe would violate federal credit regulations or other regulatory limitations; however, LPL will have no responsibility or liability for failing to cancel any order. Brochure Supplements Accompanying this Brochure are Brochure Supplements for individual employees or officers of LPL. Note that although these individuals are responsible for certain investment advice provided by LPL, they are not responsible for the ongoing individualized investment advice provided to a particular client. For more information about the Advisor, client should refer to the Advisor’s Firm Brochure, which should have been provided at the time client opened the account. If client did not receive Advisor’s Firm Brochure, the client should contact the Advisor. A 1 2 – R – 1 0 2 5 P a g e 1 9 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS March 31, 2025 1055 LPL Way Fort Mill, SC 29715 (704) 733-3300 www.lpl.com Marc Andrew Zabicki Louis James Carpenetti Garrett Fish Jason Hoody Kristian Kerr Jeffrey Roach Adam Turnquist Lawrence Dean Gillum Jina Yoon Quincy Krosby Thomas Shipp Craig Brown Scott Froidl Jeffrey Alan Buchbinder 201 Washington Street, Suite 300 Boston, MA 02108 (617) 423-3644 George Smith 4707 Executive Drive San Diego, CA 92121 (858) 450-9606 These Brochure Supplements provide information about certain LPL employees or officers that supplements the LPL Financial Brochure that is attached to these Brochure Supplements. Please contact LPL Financial at the number above if you did not receive the LPL Financial Brochure or if you have any questions about the contents of these Brochure Supplements. You may also contact your LPL investment advisor representative with questions. Additional information about these LPL employees or officers is available on the SEC’s website at https://adviserinfo.sec.gov/. Note that although these LPL employees or officers included in these Brochure Supplements are responsible for investment advice provided by LPL they are not the IARs responsible for the ongoing individualized investment advice provided to a particular client. For more information about the IAR managing the account, client should refer to the Brochure Supplement for the IAR, which should have been provided by the IAR along with the LPL Financial Brochure and these Brochure Supplements at the time client opened the account. If client did not receive a Brochure Supplement for the IAR, the client should contact the IAR or LPL at lplfinancial.adv@lplfinancial.com. Marc Andrew Zabicki Educational Background and Business Experience tying a portion of the compensation to Marc Zabicki was born in 1966. He has a BS in Economics from Florida State University and he is a Chartered Financial Analyst (CFA). He is Chief Investment Officer and the Director of Research for LPL Research and has been with the firm since 2020. Prior to joining LPL, he was Chief Investment Officer at Bower Hill Capital Management. Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and the outperformance of all LPL managed portfolios. Disciplinary Information Supervision None. Other Business Activities Mr. Zabicki is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation Mr. Zabicki is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs, and he reports to Rob Pettman, Executive Vice President. The advice provided by Mr. Zabicki is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The Chief Compliance Officer (“CCO”), Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Mr. Zabicki receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 1 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS Louis James Carpenetti Educational Background and Business Experience is a Senior Vice President and Head of Model Portfolio Management at LPL and joined LPL in 2022. Prior to joining LPL, Mr. Fish was a Portfolio Manager at JPMorgan Asset Management. Disciplinary Information None. Other Business Activities Louis James Carpenetti was born in 1971. He has a BS in Management from Palm Beach Atlantic University, an MBA from Georgia College & State University, a CFA Charterholder and has earned the CFP® certification. He is a Senior Vice President of Trading at LPL and joined LPL in July 2021. Prior to joining LPL, Mr. Carpenetti was Managing Director for Truist for 22 years serving in a variety of management and trading capacities. Disciplinary Information Mr. Fish is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. None. Additional Compensation Other Business Activities Mr. Carpenetti is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation tying a portion of the compensation to Mr. Fish receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, the and outperformance of all LPL managed portfolios. Supervision tying a portion of the compensation to Mr. Carpenetti receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, the and outperformance of all LPL managed portfolios. Supervision Mr. Fish reports to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Fish is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Jason Hoody Educational Background and Business Experience As a Senior Vice President, Mr. Carpenetti is responsible for trade execution in LPL’s advisory programs, subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Garrett Fish Educational Background and Business Experience Jason Hoody was born in 1975. He has a BS in Political Science from Clarkson University, an MA in International Affairs from American University, an MS in Finance from Johns Hopkins University, and is a CFA Charterholder. He is a Senior Vice President in Research at LPL and joined LPL in 2015. Prior to joining LPL, he was a Vice President at BB&T and an analyst at KPMG. Garrett Fish was born in 1969. He has a BA in Japanese History from Bates College and is a CFA Charterholder. He B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 2 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS Additional Compensation Disciplinary Information None. Other Business Activities None. Additional Compensation tying a portion of the compensation to Mr. Kerr receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and the outperformance of all LPL managed portfolios. Supervision tying a portion of the compensation to Mr. Hoody receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, the and outperformance of all LPL managed portfolios. Supervision Mr. Kerr reports to Mr. Zabicki, the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Kerr is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Jeffrey Roach Educational Background and Business Experience in 1973. He has a BS Mr. Hoody reports to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Hoody is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Kristian Kerr Educational Background and Business Experience in 1977. He has a BBA Jeffrey Roach was born in Mathematics from Bob Jones University and a MA and PhD in Economics from Clemson University. He is Chief Economist at LPL and joined LPL in 2022. Prior to joining LPL, Dr. Roach was Senior US Economist for Visa Inc, Managing Director, Economist at MacroView Partners and Chief Economist at Horizon Investments. Disciplinary Information None. Other Business Activities Kristian Kerr was born in International Business from Schiller International University in Madrid, Spain. He is a Senior Vice President and the Head of Macro Strategy at LPL and joined LPL in 2023. Prior to joining LPL, Mr. Kerr worked at Citi Private Bank as the Western Region Head of Foreign Exchange & Macro. Disciplinary Information None. Dr. Roach is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Other Business Activities Additional Compensation Mr. Kerr does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Dr. Roach receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 3 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS capping the amount of compensation paid regardless of the return, and tying a portion of the compensation to the outperformance of all LPL managed portfolios. Supervision tying a portion of the compensation to Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and the outperformance of all LPL managed portfolios. Supervision Mr. Turnquist reports up to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Turnquist is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Lawrence Dean Gillum Educational Background and Business Experience Dr. Roach reports to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Dr. Roach is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Adam Turnquist Educational Background and Business Experience Lawrence Gillum was born in 1974. He has a BS from University of Florida and a Master in Business Administration from the University of North Carolina, Keenan Flagler Business School. He is a Vice President of Research at LPL and joined LPL in 2021. Prior to joining LPL, Mr. Gillum served as a Director at Raymond James where he oversaw fixed income research within the firm’s discretionary model platform. Disciplinary Information Adam Turnquist was born in 1984. He has a BS from the University of Minnesota-Duluth and an MBA from the University of St. Thomas. He is Chief Technical Strategist and joined LPL in 2022. Prior to joining LPL, Mr. Turnquist worked as a Vice President, Technical Research Analyst at Piper Sandler. None. Disciplinary Information Other Business Activities None. Other Business Activities Mr. Gillum is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation is a registered representative of LPL. Mr. Turnquist However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation Mr. Gillum receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, Mr. Turnquist receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short- term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 4 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS tying a portion of the compensation to the Supervision and outperformance of all LPL managed portfolios. Supervision Ms. Yoon reports up to Mr. Zabicki, the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Ms. Yoon is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Quincy Krosby Educational Background and Business Experience Mr. Gillum reports up to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Gillum is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Jina Yoon Educational Background and Business Experience Quincy Krosby was born in 1948. She has an MPhil and PhD from The London School of Economics. She is Chief Global Strategist at LPL and joined LPL in 2022. Prior to joining LPL, Ms. Krosby worked at Prudential Financial as Chief Market Strategist. is Chief Alternate Disciplinary Information None. Other Business Activities Jina Yoon was born in 1983. She has a BS and MEng from Investment Cornell University. She Strategist at LPL and joined LPL in 2023. Prior to joining LPL, Ms. Yoon was the Head of Portfolio Management & Senior Portfolio Manager at Nomura Private Capital. Prior to Nomura, she served both Institutional and Private Wealth Clients as the Head of Tactical Strategies at Credit Suisse. Disciplinary Information None. Ms. Krosby is a registered representative of LPL. However, she does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Other Business Activities Additional Compensation Ms. Krosby receives a regular salary. Supervision Ms. Yoon does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation Ms. Krosby reports to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. This is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Ms. Yoon receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short- term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and tying a portion of the compensation to the outperformance of all LPL managed portfolios. B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 5 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS Thomas Shipp Educational Background and Business Experience University and a MAIS in Computational Social Science from George Mason University. He is a Vice President and Head of Quant Strategy at LPL and joined LPL in 2021. Prior to joining LPL, Mr. Brown was a Senior Associate in Investment Analytics and Data at Dimensional Fund Advisors. Disciplinary Information None. Thomas Shipp was born in 1984. He has a BS in Business Administration from Fordham University and is a CFA Charterholder. He is a Vice President and Head of Equity Research at LPL and joined LPL in 2017. Prior to joining LPL, Mr. Shipp was an Associate in the Equity Research Department at BMO Capital Markets. Other Business Activities Disciplinary Information None. Mr. Brown does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Other Business Activities Additional Compensation Mr. Shipp is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation Mr. Brown receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short- term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and tying a portion of the compensation to the outperformance of all LPL managed portfolios. Supervision Mr. Shipp receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short- term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and tying a portion of the compensation to the outperformance of all LPL managed portfolios. Supervision Mr. Brown reports to Mr. Zabicki, the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Brown is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Scott Froidl Educational Background and Business Experience Mr. Shipp reports to Mr. Zabicki, the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Shipp is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Craig Brown Educational Background and Business Experience Scott Froidl was born in 1971. He has a BS from Lindenwood University. He is an Assistant Vice President Senior Investment Analyst at LPL and joined LPL in 2021. Prior to joining LPL, Mr. Froidl was a Senior Investment Analyst at Wells Fargo from 2018 until 2021 and Senior Investment Analyst at Stifel in 2018 while starting with the firm in 2001. Craig Brown was born in 1988 He has a dual BS in Economics and Information Analysis from James Madison B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 6 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS Other Business Activities Disciplinary Information None. Other Business Activities Mr. Buchbinder is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation Mr. Froidl is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation tying a portion of the compensation to Mr. Buchbinder receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, the and outperformance of all LPL managed portfolios. Supervision Mr. Froidl receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short- term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and tying a portion of the compensation to the outperformance of all LPL managed portfolios. Supervision Mr. Buchbinder reports up to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Buchbinder is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. George Smith Mr. Froidl reports to Mr. Zabicki, the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Froidl is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Educational Background and Business Experience Jeffrey Alan Buchbinder in 1983. He has a BS Educational Background and Business Experience in George Smith was born Mathematics from the University of Bristol in the United Kingdom (UK). He is Portfolio Strategist at LPL and joined LPL in 2013. Prior to joining LPL, Mr. Smith worked in London, UK for Legal and General Investment Management (LGIM) and Goldman Sachs Asset Management (GSAM). Disciplinary Information None. Jeffrey Alan Buchbinder was born in 1971. He has a BA in Economics from Northwestern University and an MBA from Duke University. He is Chief Equity Strategist and Portfolio Manager for LPL Financial Research and has been with the firm since 2003. Prior to joining LPL, he served as an Equity Research Associate at Sanford C. Bernstein. Prior to Bernstein, he was an Equity Research Associate at Deutsche Bank. Other Business Activities Disciplinary Information None. Mr. Smith is a registered representative of LPL. However, he does not engage in the sale of securities or receive B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 7 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS commissions or other compensation based on the sale of securities or other investment products. Additional Compensation Mr. Smith receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short- term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and tying a portion of the compensation to the outperformance of all LPL managed portfolios. Supervision Mr. Smith reports up to Mr. Zabicki, the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Smith is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877- 7210. B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 8 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C 

OPTIMUM MARKET PORTFOLIOS (OMP) PROGRAM BROCHURE LPL Financial LLC 1055 LPL Way, Fort Mill, SC 29715 www.lpl.com (704) 733-3482 October 22, 2025 This program brochure provides information about the qualifications and business practices of LPL Financial (“LPL”). If you have any questions about the contents of this brochure, please contact LPL at lplfinancial.adv@lplfinancial.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about LPL also is available on the SEC’s website at https://adviserinfo.sec.gov. ITEM 1 COVER PAGE ITEM 2 MATERIAL CHANGES The following is a summary of certain changes made to this Brochure from the time of the initial filing dated November 8, 2024. Item 6 was updated to provide that effective November 24, 2025, LPL will be responsible for voting proxies solicited by, or with respect to, the issuers of any securities held in the account, except to the extent otherwise prohibited by law and unless clients opt to retain voting responsibility. Additional risk disclosures were added in Item 6 related to third-party service providers’ or any counterparties’ potential use of artificial intelligence and machine learning. Item 9 was updated to provide information regarding disciplinary events involving (i) a settlement with the SEC that included a $50 million fine for failing to maintain required records of certain business-related communications; and (ii) a settlement with the SEC that included an $18 million fine for LPL not following its anti-money laundering policies for its customer identification program and ongoing customer due diligence obligations. Item 9 was also updated to reflect the following setup fee charges payable to LPL by model managers or product sponsors, if applicable to the program: (i) a yearly $5,000 per strategy fee for annual due diligence reviews and maintenance; (ii) the one-time sponsor- level mutual fund setup fee was reduced from $40,000 to $15,000, with the per-fund setup fee increasing from $5,000 to $7,500; (iii) up to $15,000 as a sponsor level due diligence fee for exchange traded products; and (iv) a $5,000 per-trust fee for each unit investment trust. In addition, Item 9 was updated to disclose conflicts related to LPL’s decision to make certain product sponsors available on the applicable platforms when certain sponsors reimburse LPL for technology development related costs associated with the launch or maintenance of a platform, tool, or service. Item 9 was also updated to disclose risks related to LPL’s ability to block or review client orders before they are directed to an exchange or market maker for execution. This may result in a delay in execution, which could cause (i) a difference between execution price and the displayed quote at the time the order was entered; and (ii) a limit order becoming ineligible for execution. Item 9 was also updated to include additional information about LPL’s Dividend Reinvestment Program (DRP). ITEM 3 TABLE OF CONTENTS ITEM 1 COVER PAGE ............................................................................................................................................. 1 ITEM 2 MATERIAL CHANGES ............................................................................................................................... 1 ITEM 3 TABLE OF CONTENTS .............................................................................................................................. 1 ITEM 4 MATERIAL SERVICES, FEES AND COMPENSATION ................................................................................ 2 ITEM 5 ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ............................................................................ 6 ITEM 6 PORTFOLIO MANAGER SELECTION AND EVALUATION........................................................................ 6 ITEM 7 CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS .......................................................... 9 ITEM 8 CLIENT CONTACT WITH PORTFOLIO MANAGERS ................................................................................. 9 ITEM 9 ADDITIONAL INFORMATION .................................................................................................................... 9 A 1 2 – L P L E – 1 0 2 5 P a g e 1 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE ITEM 4 MATERIAL SERVICES, FEES AND COMPENSATION Services LPL sponsors various types of advisory programs, including wrap fee programs, an advisor-enhanced digital advice program, and mutual fund asset allocation programs. LPL makes these programs available to clients directly and also through affiliated and unaffiliated investment adviser firms, including its affiliate, LPL Enterprise, LLC (“LPLE”), and their associated persons. LPLE is a registered investment adviser and broker-dealer that offers investment advisory and brokerage services through a network of financial professionals. This Brochure provides a description of LPL’s Optimum Market Portfolios (“OMP” or “Program”) when offered through an LPLE. In instances where programs are managed by affiliates, such as this Program, affiliates are compensated for performance that service, which creates a potential conflict of interest whereby we, or our affiliates, earn additional compensation. For more information about LPL’s or LPLE’s advisory services and programs other than OMP, please contact LPL or LPLE, respectively for a copy of a similar brochure that describes such service or program or go to https://adviserinfo.sec.gov. Investment Adviser Representatives (“IARs”) are required by applicable rules and policies to obtain licenses and complete certain training in order to recommend certain investment products and services. You should be aware that your LPLE IAR, depending on the licenses or training obtained, may or may not be able to recommend certain investments, models, programs, or services. In addition to being registered as an investment adviser with the SEC, LPLE is a broker-dealer registered with the Financial Industry Regulatory Authority (“FINRA”), and your IAR also may be registered with LPLE as a broker-dealer registered representative. Therefore, your IAR may be able to offer a client both investment advisory and brokerage services. Before engaging with an IAR, clients should take time to consider the differences between an advisory relationship and a brokerage relationship to determine which type of service best serves the client’s investment needs and goals. All recommendations regarding advisory accounts will be in an advisory capacity, and any recommendations regarding any brokerage account will be in a brokerage capacity, unless a client is expressly told otherwise. Clients should speak to their IAR to understand the different types of services available through LPLE. Not all IARs of LPLE have access to all products and services. The OMP Program is a professionally managed mutual fund asset allocation program in which LPL and LPLE provide ongoing investment advice. LPLE, through its IAR, obtains the necessary financial data from the client, assists the client in determining the suitability of the Program and assists the client in setting an appropriate investment objective. LPLE, through IAR, selects a model portfolio of mutual funds (“Portfolio”) designed by LPL’s Research Department consistent with the client’s stated investment objective. The Portfolios are made up of mutual funds in the Optimum Funds mutual fund family. A Portfolio may include up to six Optimum Funds. LPL has discretion to buy and sell securities in the account and will invest the account based on the Portfolio selected. LPL rebalances accounts based on the allocations in the Portfolio as described below. LPL reviews the account for rebalancing on the frequency selected by the client at account opening or as altered by LPLE, through its IAR, or the client from time to time. The choices for frequency of rebalancing are quarterly (four times per year), semi-annually (two times per year) or annually (once per year). Accounts are reviewed on the frequency selected based on the anniversary date of account opening to determine if rebalancing is necessary. An additional rebalance may be requested outside of the scheduled frequency once every 12 months. At each rebalancing review date, accounts are rebalanced if the Account has available cash for investment and at least one of the account positions is outside a range determined by LPL, subject to a minimum transaction amount established by LPL in its discretion. In addition, LPL may review the account for rebalancing in the event that LPL Research changes the model portfolio. All recommendations by LPL or LPLE regarding accounts in the OMP program will be in an advisory capacity. LPL may accommodate requests for all or a portion of the assets in the account to remain allocated to cash for a period of time. Such customized Portfolio requests, liquidation requests in connection with withdrawals, and changes to the Portfolio or investment objective selected may take up to 5 business days to process, and, in certain circumstances, may take longer. LPL invests deposits in an account according to the Portfolio, but such deposits (or a portion thereof) may be liquidated and the proceeds may remain in cash until certain conditions are met related to trade size and position deviation from the target allocation. Although OMP accounts are not considered tax efficient or tax managed, LPL may delay placing transactions on non- A 1 2 – L P L E – 1 0 2 5 P a g e 2 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE retirement accounts by one day for any rebalancing scheduled to occur on the first one-year anniversary date of the account opening in an attempt to limit the tax treatment of realized short-term gains for any position being sold. LPL may also apply discretion to deviate from the model portfolios in accounts, in which it is not possible or impractical to be invested in all of a model’s holdings, for example in smaller accounts. In connection with the program, LPL also acts as custodian to accounts, provides research information to LPLE, provides brokerage services as the broker-dealer on transactions, and performs administrative services, such as performance information. LPLE IARs may, in their sole discretion and as agreed from time to time with clients, provide financial planning or financial consulting services to clients in connection with the program at no additional cost. IARs may also require clients to enter into a separate agreement with an agreed upon fee for financial planning or financial consulting services. The scope and duration of financial planning and consulting services varies, will generally be agreed upon at the time the IAR provides the services, and may include comprehensive financial planning or consulting on a particular issue such as retirement planning, education planning, estate planning, cash flow/budget planning, risk management planning, personal wealth planning, tax planning, business planning, investment planning/asset allocation, or other planning as needed. Financial planning and consulting may or may not include a written, customized financial plan. Fee Schedule Clients in the OMP Program pay an annualized fee (“Account Fee”) for the asset management services of LPL and LPLE, as well as the administrative and custodial services of LPL. The Account Fee is negotiable between the client and LPLE and is based on the value of assets in the Account, including cash holdings, and payable quarterly in advance. The maximum Account Fee is 2.50%. Upon request, the Account Fee also may be structured on a tiered basis, with a reduced percentage rate based on reaching certain thresholds. LPL reserves the right to increase the upper limit of the Account Fee range upon 30 days’ prior notice to clients. LPL, LPLE, and IARs do not charge performance-based fees to accounts in the OMP program. LPL retains a portion of the Account Fee for its administrative and custodial services. LPLE shares between 90% to 100% of the remaining portion of the Account Fee with the unaffiliated financial institution on the premises of which an IAR offers advisory services based on the agreement between LPLE and the financial institution. How the Account Fee is Charged LPL deducts the Account Fee and other fees and charges associated with an OMP account from the account. LPL retains amounts described above under “Fee Schedule” for services provided and pays the applicable portion of the Account Fee to LPLE and unaffiliated financial institutions with whom LPLE has agreements described herein. LPL calculates and deducts the Account Fee in the method described in the Account Agreement, unless other arrangements are made in writing. If a client wishes to be billed for the Account Fee, rather than a deduction directly from the account, the client needs to make a request to LPL through LPLE. Payment in Advance and Refund of Pre-Paid Fees LPL deducts the Account Fee quarterly in advance. If the Account Agreement is terminated before the end of the quarterly period, LPL will pay the client a prorated refund of any pre-paid quarterly Account Fee based on the number of days remaining in the quarter after the termination date. However, if the account is closed within the first six months by the client or as a result of withdrawals that bring the account value below the required minimum, LPL and LPLE reserve the right to retain the pre-paid quarterly Account Fee for the current quarter in order to cover the administrative costs of establishing the account (for example, the costs related to transferring positions in and out of the account, data entry in opening the account, reconciliation of positions in order to issue performance information, and re-registration of positions). A 1 2 – L P L E – 1 0 2 5 P a g e 3 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE Other Types of Direct Fees and Expenses of LPL In addition to the Account Fee, LPL assesses a transaction charge of $5 on each purchase and sale transaction. The transaction charge is identified under the service charge column on trade confirmations and represents a payment for expenses associated with trade execution and processing, including for preparing, printing and/or delivering confirmations. Transaction charges are waived if eligible contribution within the previous 365 days, including transfers, wires, checks, ACH or journal, are made in the account. LPL does not share any portion of the transaction charge with the IAR. Transaction charges present conflicts of interest. For example, where transaction charges apply, the more transactions Client enters into, the more compensation LPL receives. The transaction charge may be higher or lower than commissions otherwise payable in the absence of the Account Fee. When an investment change is made to the account (e.g., for transactions resulting from contributions, rebalancing, model changes, and withdrawals), the transaction charge can represent a meaningful cost to Client, in particular, at smaller account sizes. LPL does not share any portion of the transaction charge with LPLE or its IARs. Clients also pay LPL other additional miscellaneous administrative or custodial-related fees and charges that apply to an OMP account. LPL notifies clients of these charges at account opening and makes available a current list of these charges on its website at lpl.com/disclosures.html. These fees include retirement account fees and termination fees, including, for example, a fee for loans processed for qualified retirement plan and 403(b)(7) plan accounts and an account termination fee for processing a full account transfer to another financial institution. These charges are not directly based on the costs of the transaction or service by LPL, may include a profit to LPL, and certain of the fees may be lowered or waived for certain clients. Fees Charged by Third Parties, Including the Optimum Funds There are other fees and charges that are imposed by third parties other than LPL and LPLE that apply to investments in OMP accounts. In OMP, assets are invested in mutual funds and, therefore, there are two layers of advisory fees and expenses for those assets. As a shareholder of a Fund, Client will pay an advisory fee to the investment advisor of the Optimum Funds and other expenses charged by the Funds. Client will also pay LPL and LPLE the Account Fee with respect to assets invested in the Funds. The Optimum Funds or funds with similar investment objectives may be purchased directly outside of the Program. Therefore, clients could generally avoid the second layer of fees by not using the advisory services of LPL and LPLE and by making their own decisions regarding mutual fund investing. The amount of the advisory fees and other expenses of the Optimum Funds are set out in the prospectus and financial statements of the Optimum Funds, which are available upon request from LPLE or the Optimum Funds directly. Clients should understand that in many cases the mutual funds and mutual fund share classes offered through the Program charge higher fees and expenses than those that are not offered through the Program, and such other mutual funds and share classes may be equally or more appropriate for a client’s account. As discussed below, Client should understand that a portion of the fees and expenses Client pays as a shareholder of the Optimum Funds is used by the sponsor of the Funds to pay LPL for services LPL provides with respect to the funds. See Item 9, “Participation or Interest in Client Transactions,” for more information on the payments received by LPL with respect to the Optimum Funds. Other financial services firm may offer the same mutual funds that are offered through the Program but at lower overall costs to investors than the costs that clients incur by investing through the Program. If client transfers into an OMP account a previously purchased mutual fund, and there is an applicable contingent deferred sales charge on the fund, client will pay that charge when the mutual fund is sold. If the account is invested in a mutual fund that charges a fee if a redemption is made within a specific time period after the investment, client will be charged a redemption fee. Depending on the share class and fee structure of the previously purchased mutual fund, LPL can receive fees such as 12b-1 fees from the previously purchased mutual fund until the position is liquidated and subsequently invested according to the OMP model. Any 12b-1 fees paid to LPL by mutual funds transferred into an account will be credited to the client’s account. If a mutual fund has a frequent trading policy, the policy can limit a client’s transactions in shares of the fund (e.g., for rebalancing, liquidations, deposits or tax harvesting). Decisions regarding the sale of mutual funds in an account may be made by LPL and LPLE without regard to whether a client will be assessed a redemption fee. Clients can find more information regarding the fees A 1 2 – L P L E – 1 0 2 5 P a g e 4 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE and expenses of a mutual fund or ETF in the fund’s prospectus, which is available upon request from LPLE or directly from the fund. When transferring securities into an OMP account, client should be aware that certain securities are not be eligible for the account. In such case, the securities may be rejected, sold after the transfer, or moved to a brokerage account. Note that when an ineligible security is transferred into an account and subsequently sold or moved to a brokerage account, the advisory fee will be charged on such asset for the period of time the security was held in the account. Client should be aware that securities transferred into an account may have been subject to a commission or sales load when the security was originally purchased. After transfer into an OMP account, client should understand that an advisory fee will be charged based on the total assets in the account, including the transferred security. When transferring securities into an account, client should consider and speak to their IAR about whether: (cid:120) (cid:120) (cid:120) a commission was previously paid on the security; client wishes for the security to be managed as part of the account and be subject to an advisory fee; or client wishes to hold the security in a brokerage account that is not managed and not subject to an advisory fee. Important Things to Consider About Fees on an OMP Account type and size of the account (cid:120) The Account Fee is a single fee for investment advisory services and other administrative and custodial services. Clients do not pay a commission to LPL or LPLE but do pay a transaction charge (unless waived) as described above. The Account Fee may cost the client more than purchasing the Program services separately, for example, paying an advisory fee plus commissions to a broker-dealer for each transaction in the account. Factors that bear upon the cost of the account in relation to the cost of the same services purchased separately include the: (cid:120) (cid:120) historical and or expected size or number of trades for the account, and (cid:120) number and range of supplementary advisory and client-related services provided to the client. (cid:120) (cid:120) The Account Fee may be higher than the fees charged by other investment advisors for similar services. This is the case in particular if the Account Fee is at or near the maximum Account Fee set out above. LPLE, through its IAR is responsible for determining the Account Fee to charge each client based on factors such as total amount of assets involved in the relationship and the complexity, number and range of supplementary advisory and client-related services to be provided to the account. Clients should consider the level and complexity of the advisory services to be provided when negotiating the Account Fee with LPLE through its IAR. LPLE and IAR receive compensation as a result of recommending a client’s participation in the Program. The amount of this compensation may be more or less than what LPLE or IAR would receive if the client participated in other LPL or LPLE programs or paid separately for investment advice, brokerage and other client services, particularly where LPLE or IAR retains a greater portion of the Account Fee or additional cash or non-cash compensation, even though the client’s fee remains the same. Based on the compensation structure between the financial institution and IAR, IAR can have a financial incentive to recommend the Program over other programs and services. This compensation includes a portion of the Account Fee and also may include other compensation, such as bonuses, awards or other things of value offered by LPL or LPLE to IARs. However, LPLE and IAR intend to make all recommendations independent of such considerations and based solely on their obligations to consider client’s objectives and needs. (cid:120) The investment products available to be purchased in the Program can be purchased by clients outside of an OMP account, through broker-dealers or other investment firms not affiliated LPL. (cid:120) Clients should consider the impact of fees and expenses on their investment portfolio, as described in the informational brochure titled “How Fees and Expenses Affect Your Portfolio” on lpl.com/disclosures.html under “Investor Regulatory & Educational Resources.”(cid:3) A 1 2 – L P L E – 1 0 2 5 P a g e 5 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE ITEM 5 ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS LPL generally requires a minimum account value of $1,000, but eligible contribution within the previous 365 days, including transfers, wires, checks, ACH or journal, are required for account sizes below $10,000. In certain instances, LPL will permit a lower minimum account size. An account will not be invested according to the Portfolio until the minimum has been reached. The Program is available for individuals, individual retirement accounts (“IRAs”), banks, thrift institutions, credit unions, pension and profit-sharing plans, including plans subject to Employee Retirement Income Security Act of 1974 (“ERISA”), trusts, estates, charitable organizations, state and municipal government entities, corporations and other business entities. ITEM 6 PORTFOLIO MANAGER SELECTION AND EVALUATION In OMP, LPL and LPLE do not select, review or recommend the services of other investment advisor or portfolio management firms. LPL and LPLE are responsible for the investment advice and management offered to clients, and the client selects the IAR who services the account. Each IAR is generally required to possess a FINRA Series 65 or 66 license (to the extent required). For more information about the IAR managing the account, client should refer to the Brochure Supplement for the IAR, which client should have received at the time client opened the account. In OMP, clients invest in Portfolios designed by LPL’s Research Department. LPL Research designs different types of Portfolios for OMP to meet the varying needs of clients. LPLE, through its IAR, selects the Portfolio and provides advice based on the client’s individual needs. LPL receives a portion of the Account Fee for the Portfolio design services of LPL Research. LPL, LPLE and its IARs do not accept performance-based fees under OMP. LPL’s Research Department uses the following investment strategies in designing Portfolios. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. Investing in securities involves the risk of loss that clients should be prepared to bear. Each of these investment strategies seek to generate capital appreciation while assuming a reasonable amount of risk. (cid:120) Standard. These Portfolios invest in up to six Optimum Funds across the following asset classes: large growth, large value, small/mid growth, small/mid value, international, and fixed income. (cid:120) U.S. These Portfolios invest in up to five Optimum Funds across the following asset classes: large growth, large value, small/mid growth, small/mid value, and fixed income. These Portfolios do not invest in international. (cid:120) Growth Tilt. These Portfolios invest in up to six Optimum Funds across the following asset classes: large growth, large value, small/mid growth, small/mid value, international, and fixed income. These Portfolios are over-weighted to growth relative to the standard models. (cid:120) Value Tilt. These Portfolios invest in up to six Optimum Funds across the following asset classes: large growth, large value, small/mid growth, small/mid value, international, and fixed income. These Portfolios are over-weighted to value relative to standard models. For Standard and U.S. Portfolios described above, LPL Research makes available a strategic or tactical version for each Portfolio. The strategic Portfolios are intended to take advantage of market opportunities that will occur or persist over a three-to-five-year time frame. The tactically managed Portfolios are intended to take advantage of short-, medium-, or long-term opportunities. In addition, for the Standard Portfolios there are two different versions of the tactically managed portfolios: Traditional Standard and Spectrum Standard. The asset allocation of the Traditional Standard Portfolios is set primarily leveraging the LPL Research macroeconomic views. The asset allocation of the Spectrum Standard Portfolios is set primarily leveraging the LPL Research diligence views. Types of Investments and Risks Investing in securities involves the risk of loss that clients should be prepared to bear. Described below are some risks associated with investing. (cid:120) Market Risk. This is the risk that the value of securities owned by an investor may go up or down, sometimes rapidly or unpredictably, due to factors affecting securities markets generally or particular industries. A 1 2 – L P L E – 1 0 2 5 P a g e 6 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE (cid:120) Interest Rate Risk. This is the risk that fixed income securities will decline in value because of an increase in interest rates; a bond or a fixed income fund with a longer duration will be more sensitive to changes in interest rates than a bond or bond fund with a shorter duration. (cid:120) Economic Conditions Risk. This is the risk that economic, political or financial developments will, from time to time, result in periods of volatility or other adverse effects that could negatively impact your account. (cid:120) Credit Risk. This is the risk that an investor could lose money if the issuer or guarantor of a fixed income security is unable (cid:120) or unwilling to meet its financial obligations. Investment Company Risk. To the extent a client account invests in ETFs or other investment companies, its performance will be affected by the performance of those other investment companies. Investments in ETFs and other investment companies are subject to the risks of the investment companies’ investments, as well as to the investment companies’ expenses. If a client account invests in other investment companies, the client account may receive distributions of taxable gains from portfolio transactions by that investment company and may recognize taxable gains from transactions in shares of that investment company, which would be taxable when distributed. (cid:120) Pledging Assets. LPL has partnered with certain banks to help facilitate clients’ access to collateralized non-purpose lines of credit; however, clients are not required to use the banks in LPL’s Program, and can work directly with other banks (“non- partner banks”) to negotiate loan terms or obtain other financing arrangements. Clients who choose to use non-partner banks should notify IAR of the amount of the line of credit. In these collateralized lending arrangements, clients borrow from the bank and pay interest to the bank. In some cases, LPLE, through its IAR, may recommend that a client seeking to access funds (for purposes other than purchasing securities) hold his securities investments and instead utilize a non- purpose line of credit collateralized by the assets in his advisory account. Unless LPLE, through its IAR, specifically recommends that a client hold his securities investments and instead utilize a collateralized line of credit to access funds, the decision regarding whether to arrange for a collateralized loan and the decision to draw down on such a loan are not covered by a client’s advisory relationship with LPL, LPLE or IAR. While LPLE, through its IAR, may assist the client with facilitating a line of credit, clients are responsible for independently evaluating the terms of the loan and deciding whether the loan meets their needs. Clients also should be aware that pledging assets in an account to secure a loan involves additional risks. The bank holding the loan has the authority to liquidate all or part of the securities at any time without your prior notice in order to maintain required maintenance levels, or to call the loan at any time. As a practical matter, this may cause you to sell assets and realize losses in a declining market. Moreover, the ability of LPLE, through its IAR, to make investment decisions or recommendations for the account may be restricted by collateral requirements imposed by the bank. These restrictions or a forced liquidation may interfere with your long-term investment goals and/or result in adverse tax consequences. Further, you should note that the returns on accounts or on pledged assets may not cover the cost of loan interest and advisory fees. Clients should be aware that LPL’s collateralized loan program is one way, among many, for clients to raise necessary cash. Before pledging assets in an account, clients should carefully review the loan agreement, loan application and any forms required by the bank and any other forms and disclosures provided by LPL. For a list of the banks currently participating in LPL’s collateralized lending program, please visit lpl.com/disclosures.html, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Third Party Compensation and Related Conflicts of Interest.” (cid:120) Cybersecurity Risk. Failures or breaches of the electronic systems of LPL or LPLE, its service providers, securities market participants or the issuers of securities can cause significant losses for investors. Unintentional cyber events, such as the inadvertent release of confidential information, could also adversely impact investor account. Any cyber event could cause result in the loss or theft of investor data or cause investors financial loss and expense. (cid:120) Use of Artificial Intelligence and Machine Learning. Recent technological advances in artificial intelligence, generative artificial intelligence, and machine learning technology (collectively, “Machine Learning Technology”) may pose risks to LPL and LPLE. LPL and LPLE could be further exposed to the risks of Machine Learning Technology if third-party service providers or any counterparties, whether or not known to LPL or LPLE, also use Machine Learning Technology in their business activities. LPL and LPLE will not be in a position to control the operations of third-party service providers or counterparties, the manner in which third-party products are developed or maintained or the manner in which third-party A 1 2 – L P L E – 1 0 2 5 P a g e 7 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE services are provided. Machine Learning Technology is generally highly reliant on the collection and analysis of large amounts of data, and it is not possible or practicable to incorporate all relevant data into the model that Machine Learning Technology utilizes to operate. Certain data in such models will inevitably contain a degree of inaccuracy and error, potentially materially so, and could otherwise be inadequate or flawed, which would be likely to degrade the effectiveness of Machine Learning Technology. To the extent that LPL or LPLE are exposed to the risks of Machine Learning Technology, any such inaccuracies or errors could have adverse impacts on LPL or LPLE, as applicable. Machine Learning Technology and its applications, including in the financial services sector, continue to develop rapidly, and it is impossible to predict the future risks that will from time to time arise from such developments. (cid:120) Values-Based and Environmental, Social and Governance (ESG) Investing Risk. Values-based investing or ESG investing, also known as “socially responsible investing,” “sustainable investing,” or “impact investing,” focuses on the social values or environmental, social, and governance standards or the sustainability factors of an investment. Some values-based investing strategies focus on factors relating to an individual investor’s personal or religious values, such as “biblical investing,” while other strategies focus on issues like environmental impact. Some values-based investment strategies use values-based criteria to supplement financial analysis when considering a particular issuer or security, while others affirmatively select “socially responsible” investments or screen out or exclude investments in companies that engage in certain activities. Values-based investing may limit the type and number of investments available in a strategy and cause the strategy to underperform other strategies without a values-based focus or with a focus that involves a different type of focus or screening methodology. Values-based strategies may underperform the market as a whole. Companies and issuers selected in a values-based strategy may not or may not continue to demonstrate values-based characteristics. Different investors likely have different opinions about what types of investments are socially responsible. Voting Client Securities Unless a client instructs otherwise, effective November 24, 2025, LPL will vote proxies in accordance with its proxy voting policies and procedures then in effect, which will include engaging one or more third party proxy advisor vendors to make proxy voting recommendations and handle the administrative functions of voting proxies. For OMP, LPL’s proxy voting policies and procedures state that LPL will vote proxies in all instances in accordance with recommendations from Glass, Lewis & Co., a third-party proxy advisory services company, for any securities held in your account, except to the extent otherwise prohibited by law. For the avoidance of doubt, in the event that Glass, Lewis & Co. does not provide a recommendation, LPL will abstain from voting in that proxy campaign. Notwithstanding the foregoing, if Client is a plan subject to ERISA (as defined above), LPL shall vote client proxies in accordance with LPL’s obligations under ERISA and applicable Department of Labor Regulations. Client may expressly retain the right and obligation to vote any proxies or exercise any voluntary corporate actions relating to securities held in the Account, provided Client provides prior written notice to LPL. A copy of LPL’s proxy voting policies is available upon request to LPLE. A client can obtain information about how LPL voted with respect to securities held in the client’s account by contacting LPLE. If a client elects to retain the right and obligation to vote proxies and receive mutual fund shareholder reports, LPL is reimbursed by the proxy issuer or mutual fund for the delivery costs to send proxies and shareholder reports to the client. The maximum fee that can be charged for delivery is set by New York Stock Exchange (NYSE) rules. If LPL uses a vendor to perform the delivery, the vendor seeks reimbursement from the proxy issuer or mutual fund on LPL’s behalf and in certain cases remits a portion of the reimbursement to LPL. If clients have questions regarding the solicitation, they should contact the contact person that the issuer identifies in the proxy materials or LPLE. In addition, LPL and LPLE do not accept authority to take action with respect to legal proceedings relating to securities held in the account. A 1 2 – L P L E – 1 0 2 5 P a g e 8 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE ITEM 7 CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS LPLE, through its IAR, obtains the necessary financial data from the client and assists the client in setting appropriate investment objectives for the account. LPLE, through its IAR, obtains this information by having the client complete an Account Application which is a part of the Account Agreement. In quarterly communications, LPL asks clients to contact LPLE if there have been any changes in the client’s financial situation or investment objectives or if they wish to impose any reasonable restrictions on the management of the account or reasonably modify existing restrictions. Clients should understand that the investment objective selected for the Program in the Account Application is an overall objective for the entire account and may be inconsistent with a particular holding and the account’s performance at any time. Client also should be aware that achievement of the stated investment objective is a long-term goal for the account. ITEM 8 CLIENT CONTACT WITH PORTFOLIO MANAGERS LPL does not place any restrictions on a clients’ ability to contact and consult with LPL, LPLE or IAR. ITEM 9 ADDITIONAL INFORMATION Disciplinary Information LPL entered into a settlement with the SEC in which the SEC found that LPL willfully violated its obligations under Section 17(a) of the Exchange Act and Rule 17a-8 thereunder, which require broker-dealers to comply with certain anti-money laundering (“AML”) requirements. The SEC found that LPL did not follow its AML policies for its customer identification program and ongoing customer due diligence obligations by, among other things, not properly verifying new accounts; not timely closing accounts that did not pass its screening measures; and not closing or restricting certain accounts that were prohibited under LPL’s AML Policies. The SEC censured LPL and ordered LPL to cease and desist from committing or causing any violations and any future violations of such section and rule, to pay a civil monetary penalty in the amount of $18 million, and to comply with certain undertakings (2025). LPL entered into a settlement with the SEC in which the SEC found that LPL willfully violated Section 17(a) of the Exchange Act and Rule 17a-4(b)(4) thereunder and Section 204 of the Advisers Act and Rule 204-2(a)(7) thereunder in connection with the maintenance and preservation of off-channel communications; and failed to reasonably supervise its personnel within the meaning of Section 15(b)(4)(E) of the Exchange Act and Section 203(e)(6) of the Advisers Act. LPL admitted to the facts in the settlement order and acknowledged its conduct violated the federal securities laws. The SEC ordered LPL to cease and desist from committing or causing any violations and any future violations of Section 17(a) of the Exchange Act and Rule 17a-4(b)(4) thereunder and Section 204 of the Advisers Act and Rule 204-2(a)(7) thereunder, censured it for its conduct, ordered it to pay a civil monetary penalty in the amount of $50,000,000, and ordered it to comply with certain undertakings (2024). LPL entered into a settlement with the SEC in connection with LPL’s failure to comply with its Customer Identification Program procedures. The SEC found that LPL willfully violated Section 17(a) of the Exchange Act and Rule 17a-8 thereunder and was a cause of a third party’s violations of Sections 17(a)(2) and (3) of the Securities Act and Section 206(2) of the Advisers Act. The SEC ordered LPL to cease and desist from committing or causing any further violations of these laws and regulations, censured LPL for its conduct, and ordered the payment of disgorgement and prejudgment interest totaling $141,202 (deemed satisfied based on LPL’s voluntary remedial payment of $4,118,876 to the impacted client), and the payment of a civil money penalty of $750,000 (2021). As part of a voluntary self-reporting initiative in 2019, LPL entered into a settlement with the SEC in which the SEC found that LPL willfully violated Section 206(2) and 207 of the Investment Advisers Act of 1940 (the “Advisers Act”) in connection with inadequate disclosure to clients of its and its associated persons’ conflicts of interest related to its receipt of 12b-1 fees and/or its selection of mutual fund share classes that pay such fees. The SEC ordered LPL to cease and desist from committing or causing any violations of Sections 206(2) and 207 of the Advisers Act, censured it for its conduct, and ordered the payment of disgorgement and prejudgment interest to affected investors totaling $9,333,516 (2019). LPL, as a broker-dealer, is a member of (“FINRA”) and has found to be in violation of FINRA’s rules related to its brokerage activities. In particular, LPL consented to sanctions related to the following matters: A 1 2 – L P L E – 1 0 2 5 P a g e 9 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE (cid:120) (cid:120) (cid:120) (cid:120) (cid:120) (cid:120) (cid:120) (cid:120) (cid:120) (cid:120) LPL’s supervisory systems and maintenance of books and records relating to brokerage direct business transactions, supervisory systems and misstatements about fees relating to brokerage product switch transactions, and supervisory systems relating to brokerage recommendations of publicly traded securities of business development companies (BDCs) to customers, resulting in a censure, a fine of $5.5 million, restitution to impacted customers, and an undertaking to certify that LPL has remediated the systems and procedures for making recommendations of BDCs (2023). LPL’s supervisory systems and procedures relating to the transmittal of customer funds by wire or check to third parties and maintenance of related books and records, resulting in a censure, a fine of $3,000,000, restitution to impacted clients, and an undertaking to identify and pay restitution to affected customers for certain other improper transfers (2023). LPL’s failure to accurately calculate its customer reserve requirement, failure to maintain a sufficient customer reserve, failure to maintain policies and procedures reasonably designed to achieve compliance with the Securities and Exchange Act and FINRA rules, and failure to maintain accurate books and records, resulting in a censure and a fine of $300,000 (2022). LPL’s self-reporting of potential issues related to certain C-share purchase suitability reviews and its supervisory systems and procedures relating to waivers of front-end sales charges for rollovers of 529 savings plan investments from one state plan to another, resulting in a censure and payment of restitution to impacted customers (2021). LPL’s supervisory systems and procedures relating to record retention, fingerprinting and screening of certain associated persons, and supervision of consolidated reports, resulting in a censure, a fine of $6,500,000 and an undertaking to review and enhance related policies, systems and procedures (2020). LPL’s supervisory systems and procedures relating to changes in the authority of custodians of accounts established under the Uniform Gifts to Minors Act and/or the Uniform Transfers to Minors Act, resulting in a censure, a fine of $300,000, and an undertaking to review and enhance its policies, systems, and procedures related to supervision of such accounts (2019). (cid:120) The effectiveness of LPL’s anti-money laundering program, LPL’s failure to amend certain Forms U4 and U5, and LPL’s systems and supervisory procedures relating to Forms U4 and U5 reporting requirements, resulting in a censure and a fine of $2,750,000 and an undertaking to review the process used to disclose customer complaints on Forms U4 and U5 (2018). LPL’s brokerage supervisory and disclosure procedures related to the sale of certain brokered certificates of deposit in brokerage accounts, resulting in a censure and a fine of $375,000 (2018). LPL’s systems and supervisory procedures relating to the creation and distribution of certain required account notices, resulting in a censure, a fine of $900,000, and an undertaking to review affected processes (2016). LPL’s systems and supervisory procedures relating to the format in which certain electronic records were retained, resulting in a censure and a fine of $750,000 (2016). LPL’s various brokerage supervisory procedures, including those related to the sale of complex non-traditional ETFs, variable annuity (“VA”) contracts, real estate investment trusts (“REITs”) and other products in brokerage accounts, as well as LPL’s failure to monitor and report trades and deliver trade confirmations, resulting in a censure and a fine of $10,000,000, and restitution of $1,664,592 (2015). LPL, as a broker-dealer, is regulated by each of the 50 states and has been the subject of orders related to the violation of state laws and regulations in connection with its brokerage activities. In particular, LPL entered into consent orders related to the following matters: (cid:120) (cid:120) (cid:120) (cid:120) LPL’s supervision of electronic signature practices at an LPL branch office in Massachusetts, resulting in a fine of $250,000 and an undertaking to conduct an internal review of certain related policies and procedures (Massachusetts or “MA”, 2023). LPL’s supervision of an LPL broker-dealer/investment adviser agent’s sales of structured products, resulting in a censure, an offer of restitution to impacted clients, and a fine of $125,000 (Texas, 2022). LPL’s supervision of two LPL broker-dealer and/or investment adviser agents who pled guilty to charges of fraudulent practices with LPL customers, resulting in a cease and desist order, a fine of $350,000 and a $150,000 contribution for financial literacy and investor education initiatives, training and related materials (Connecticut, 2021). LPL’s supervision of an LPL representative under a heightened supervision plan, resulting in a cease and desist order; a fine of $275,000; payments of restitution, disgorgement and investigative costs; and offers of payment of surrender charges in connection with variable annuity contracts for impacted customers (New Hampshire or “NH”, 2020). A 1 2 – L P L E – 1 0 2 5 P a g e 1 0 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE (cid:120) (cid:120) LPL’s failure to timely register (or maintain the registration of) certain agents in MA and failure to amend Forms U4 and U5 for certain agents registered in MA, resulting in a censure, a fine of $1,100,000, and an undertaking to review and enhance its policies and procedures related to registering its agents in MA and filing reportable events (MA, 2019). LPL’s brokerage supervisory procedures relating to email review and annual branch office examinations, resulting in a civil penalty of $450,000 and an undertaking for third-party review of related processes (Indiana, 2018). (cid:120) The sale of unregistered, non-exempt securities in violation of state registration requirements, resulting (upon entry of the individual consent order) in payment to each participating state or jurisdiction of a civil penalty of $499,000, reimbursement of certain investigative expenses, remediation through repurchase of certain securities and payment of losses to certain affected customers, and certain additional undertakings (Settlement with up to 53 members of the North American Securities Administrators Association (NASAA), 2018). (cid:120) (cid:120) (cid:120) The sale of non-traded alternative investments in excess of prospectus standards or LPL’s internal guidelines and the maintenance of related books and records, resulting in a censure, a fine of $950,000, a $25,000 contribution to an investor education fund and remediation of losses to impacted customers (New Jersey, 2017). LPL’s supervisory practices for LPL representatives located on the premises of a credit union, resulting in a censure, a fine of $1,000,000, and an undertaking to avoid investor confusion specific to the name under which the credit union does business and review LPL’s related policies and procedures (MA, 2017). LPL’s oversight of certain VA transactions, resulting in a censure, a fine of $975,000, restitution to clients and former clients of an LPL representative, disgorgement of commissions retained by LPL in connection with such representative’s VA sales, and an undertaking to review such representative’s brokerage and advisory activities and LPL’s related policies and procedures (MA, 2017). (cid:120) The sale in brokerage accounts of non-traded REITs in excess of prospectus standards, state concentration limits or LPL’s internal guidelines, resulting in an aggregate civil penalty of $1,425,000, reimbursement of certain investigative expenses and remediation of losses to impacted customers (Global settlement with certain members of NASAA, 2015). (cid:120) The sale of non-traded REITs in excess of prospectus standards, state concentration limits or LPL’s internal guidelines, resulting in an administrative fine of $250,000, reimbursement of investigative costs of $250,000, a $250,000 contribution to an investor education fund and remediation of losses to impacted customers (NH, 2015). (cid:120) The sale of leveraged and inverse leveraged ETFs (“Leveraged ETFs”), resulting in an administrative fine of $50,000 (Delaware), a penalty of $200,000 (MA), restitution to Delaware customers in an amount up to $150,000, restitution to MA customers in an amount up to $1,600,000, and an agreement to make certain changes in its supervisory system with respect to Leveraged ETFs (2015). (cid:120) Failure to implement procedures related to the use of senior-specific titles by LPL representatives as required under MA law, resulting in a censure and a fine of $250,000 (2015). For more information about those state events and other disciplinary and legal events involving LPL, client should refer to Investment Adviser Public Disclosure at https://adviserinfo.sec.gov/ or FINRA BrokerCheck at https://brokercheck.finra.org/ Other Financial Industry Activities and Affiliations LPL is also a broker-dealer registered with FINRA and the SEC. As a broker-dealer, LPL transacts business in various types of securities, including mutual funds, stocks, bonds, commodities, options, private and public partnerships, variable annuities, REITs and other investment products. LPL is registered to operate in all 50 states and has primarily an independent-contractor sales force of registered representatives and investment adviser representatives dispersed throughout the U.S. LPL has a dedicated team of employee IARs in its offices who service certain accounts, and also a small subset of IARs who operate their own offices or are located on the premises of certain financial institutions and are employees of LPL Employee Services, LLC, an LPL-affiliated company. If required for their positions with a registered broker-dealer, LPL’s principal executive officers are securities licensed as registered representatives of LPL. LPL is also registered as an introducing broker with the Commodity Futures Trading Commission. In addition, LPL is qualified to sell insurance products in all 50 states. Our affiliate, LPLE, is an investment adviser registered with the SEC and a broker-dealer registered with FINRA and the SEC. As a broker-dealer, LPLE transacts business in various types of securities, including mutual funds, stocks, bonds, commodities, A 1 2 – L P L E – 1 0 2 5 P a g e 1 1 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE options, private and public partnerships, variable annuities, REITs and other investment products. LPLE is registered to operate in all 50 states and has primarily an independent-contractor sales force of registered representatives and investment adviser representatives dispersed throughout the United States. In addition, LPLE is qualified to sell insurance products in all 50 states. LPL, LPLE and The Private Trust Company, N.A. (“PTC”), a federally chartered non-depository bank licensed to provide trust services in all 50 states, are related persons. PTC serves as IRA custodian for program accounts set up as IRAs and receives an annual maintenance fee for this service. PTC also provides personal trustee services to clients for a variety of administrative fiduciary services, which services may relate to a program account. Because LPL, LPLE and PTC are affiliated companies and share in revenues, there is a financial benefit to the companies if a client uses PTC as a custodian or for personal trustee services, or if a PTC client uses LPL or LPLE as an investment advisor. PTC’s IRA custodian and trustee services and related fees are established under a separate engagement between the client and PTC. Fiduciary Trust Company of New Hampshire (“FTC”), a non-depository trust company, is a related person of LPL and LPLE. FTC provides custodial and various other recordkeeping and services to IRAs and certain employer-sponsored plans maintained through non-OMP program accounts. Because LPL, LPLE and FTC are affiliated companies and share in revenues, there is a financial benefit to the companies if a client is referred to or otherwise elects to engage with FTC for services under another LPL or LPLE program, and uses LPL or LPLE as the investment advisor or broker-dealer. FTC’s custodial and recordkeeping services and related fees are established under a separate engagement between the client and FTC. LPL and LPLE have an affiliated insurance agency, LPL Insurance Associates, Inc. (“LPLIA”) through which IARs may sell insurance products. LPL receives compensation from issuers of life insurance (universal, variable universal, whole life, and term) and other insurance contracts that are made available by IARs, such as long term care insurance and disability insurance. The compensation includes commissions and trails, and may include payments for administrative services that LPL provides and/or payments made in connection with LPL’s marketing and sales-force education and training efforts, including LPL’s annual national sales and education conference and other conferences. IARs receive a percentage of the commissions or trailing commissions paid to LPL or LPLIA. IARs may also sell insurance through an independent unaffiliated insurance agency. An IAR may earn compensation (including trailing compensation), benefits and non-cash compensation through the third party insurance agency and may have an incentive to recommend you purchase or sell insurance products with the independent agency. Code of Ethics and Personal Trading LPL and LPLE have each adopted a code of ethics that includes guidelines regarding personal securities transactions of its employees and investment adviser representatives (“IARs”). The code of ethics permits employees and LPL IARs to invest for their own personal accounts in the same securities that are purchased for clients in program accounts. This presents a conflict of interest because trading by an employee or IAR in a personal securities account in the same security on or about the same time as trading by a client can disadvantage the client. LPL and LPLE each address this conflict of interest by requiring in its code of ethics that employees and IARs report certain personal securities transactions and holdings. LPL and LPLE each have procedures to review personal trading accounts for front-running. However, since LPL’s Research Department has sole control over trading decisions (including timing of implementation thereof) for the Model Portfolios in the Program, the potential for front-running by most employees and IARs is limited, and no such review is conducted other than for employees in LPL’s Research Department. In addition, employees in LPL’s Research Department are required to obtain pre-clearance prior to purchasing certain securities for a personal account. Employees and IARs are also required to obtain pre-approval for investments in private placements and initial public offerings. A copy of the code of ethics is available to clients or prospective clients upon request and is available at lpl.com/disclosures.html and lpl.com/lpl-enterprise.html, respectively. Participation or Interest in Client Transactions Purchases of mutual fund shares may be processed through LPL’s proprietary account resulting in such purchases being characterized as principal transactions for certain reporting purposes. In such case, the shares will be purchased at the fund’s net asset value, and no additional charges will be applied to such transactions as a result of LPL’s use of a proprietary account. LPL and LPLE do not otherwise engage in principal transactions with its clients in the Program. LPL’s and LPLE’s parent A 1 2 – L P L E – 1 0 2 5 P a g e 1 2 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE company, LPL Financial Holdings Inc., is a publicly traded company. LPL Financial Holdings Inc. stock may not be purchased directly in OMP accounts. However, an OMP account may include a mutual fund that holds LPL Financial Holdings Inc. stock as an underlying investment. LPL provides investment consulting services to the investment advisor of the Optimum Funds. These services include assisting the investment advisor in determining whether to engage, maintain or terminate sub-advisors for the Optimum Funds. As compensation for these services, LPL receives an investment consulting fee of up to 0.22% of assets from the investment advisor to the Optimum Funds. In addition, a senior executive officer of LPL serves as a Trustee of the Optimum Funds. Certain of the Optimum Funds are subject to voluntary expense caps that may result in the adviser to the Optimum Funds waiving fees or reimbursing expenses that exceed those caps. The adviser to the Optimum Funds bears the cost of any reimbursements or waivers. LPL also performs recordkeeping, administrative and shareholder services on behalf of the Optimum Funds and receives compensation for the services based on the amount of Program assets that are invested in the funds (up to 0.15% annually). These services include establishing and maintaining accounts with the Optimum Funds, facilitating settlement of funds, responding to customer inquiries and requests, and maintaining sub-account records reflecting the issuance, exchange or redemption of shares by each program account. The receipt of this recordkeeping and investment consulting compensation by LPL is an important revenue stream and presents a conflict of interest, because LPL has a financial benefit the more assets that are invested in the Optimum Funds. The investment consulting and recordkeeping compensation is retained by LPL and is not shared with LPLE. Although LPL does not share investment consulting and recordkeeping compensation with LPLE or IARs, such fees and payments will increase LPL’s profits and indirectly benefit LPLE and its IARs, for example increasing the value of equity awards from LPL’s parent company to IARs or by being used by LPL to support marketing or training costs. In addition, LPL charges a setup fee to product sponsors when adding new investment products or share classes of an investment product to LPL’s investment platforms. In the case of exchange traded products, LPL receives up to $15,000 as a sponsor level due diligence fee, up to $7,500 per fund and up to an additional $15,000 per product for complex ETPs and ETPs. In the case of mutual funds, LPL receives a one-time set up fee of up to $15,000 as a sponsor level due diligence fee and a setup fee of $7,500 per fund. In the case of UITs, LPL charges up to $5,000 per trust. LPL does not share this compensation with LPLE or its IARs. LPL offers product sponsors of mutual funds, closed funds, interval funds, ETFs, alternative investments, advisory strategies, annuities and life insurance contracts the opportunity to purchase analytical data, business intelligence and ad hoc reporting. This information helps product sponsors in their sales, distribution and product development efforts with respect to customers and clients and creates similar conflicts to those discussed above. LPL receives up to $600,000 annually from each product sponsor in third party compensation for this information. Cash Sweep Service Options LPL automatically transfers cash balances (including otherwise uninvested cash amounts received from the customer, securities transactions, dividend and interest payments, and other account-related activities) in a customer’s eligible accounts through the account’s designated sweep service option, where applicable. The type of sweep service options available (and how cash is held) depends on the customer’s account type. LPL offers Federal Deposit Insurance Corporation (“FDIC”)-insured bank sweep services for most customer accounts. Accounts may be eligible for the LPL Insured Cash Account (“ICA”) Program, the LPL Deposit Cash Account (“DCA”) Program or the money market mutual fund sweep, each described below. Not all sweep service options are available to all types of customer accounts. Cash sweep is offered as an account feature and service to facilitate the operation and maintenance of the account and is not intended to be used as an investment option or as part of an account’s asset allocation, though for certain advisory accounts, it is typical for an account to have an allocation to cash to support the operational needs and fees charged to the account. LPL and its financial professionals do not typically recommend specific sweep service options or underlying sweep holdings. For more information, please see your customer agreement and the applicable ICA or DCA disclosure booklet, or the sweep money market fund prospectus. A 1 2 – L P L E – 1 0 2 5 P a g e 1 3 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE The aggregate fees and expenses received by LPL in connection with the customer account’s designated sweep service option can be higher or lower than the customer’s yields on the sweep service option depending on the particular sweep option, prevailing interest rates and other market factors. See https://www.lpl.com/disclosures/lpl-financial-fdic-insured-bank-deposit- sweep-programs.html for Information about our customer fees and customer Interest rates for ICA and DCA, or contact your LPLE IAR for information about our customer fees and customer interest rates for money market funds. Historically, customer yields in ICA have always been lower than the aggregate fees and charges received by LPL. Customer yields in DCA and in money market mutual funds have been both lower and higher than the aggregate fees and charges received by LPL. Cash sweep services are not intended to be used for long-term investments and are more appropriately viewed as an indirect cost of maintaining and operating the account. LPL makes available a wide range of investment alternatives with differing risk and return characteristics, which are better suited for meeting customer investment needs and objectives. Customers should compare the terms, interest rates, required minimum amounts and other features of their account’s applicable sweep service option available through other types of accounts and investment options available in their account. FDIC insurance protects against the loss of FDIC-insured deposits if the depository institution or bank holding the deposit fails. LPL itself is not an FDIC-insured depository institution. With respect to our sweep service options, only balances received by, and deposited at, the ICA and DCA are eligible for FDIC insurance (subject to applicable limits). Eligibility for pass-through deposit insurance coverage for ICA and DCA, deposits is subject to fulfilling specific conditions. Client Cash Accounts and money market mutual funds are not customer bank deposits and are subject to investment risks, including the potential loss of the amount invested. These investments are not FDIC-Insured, but may be subject to SIPC protection. (cid:120) Insured Cash Account (ICA). LPL's ICA sweep service option automatically sweeps otherwise uninvested cash balances held within customer brokerage (and certain advisory accounts) into interest-bearing bank deposits eligible for FDIC insurance (subject to applicable limits). Under its agreement with each ICA participating bank in which customer cash may be swept, LPL receives a fee from the bank equal to a percentage of the average daily deposit balance held at the bank. Such fees differ among the participating banks depending on the current interest rate environment and/or any fee waivers made by LPL. The fee LPL receives is generally an average aggregate annual rate of up to 6% as applied across the deposits held at all of the ICA participating banks. Because the banks generally pay different amounts to LPL on account balances, fees received by LPL with respect to a specific customer account (and the account's cash holdings) may be higher or lower than this average percentage amount. The fees received by LPL from the ICA participating banks reduce the interest rate customers receive on their cash held through ICA. These fees are additional compensation to LPL for operating and maintaining the account and for LPL’s other services to the account. LPL has chosen to offer ICA as the sole sweep service option for certain account types, in part because of the additional compensation LPL earns from the use of ICA. In situations where customer cash balances allocated through ICA exceed the deposit availability at ICA participating banks, uninsured cash balances may be placed into an “overflow” Client Cash Account. Such balances are considered to be “free credit balances” and represent a direct liability of LPL to the customer. See below for information about how LPL is compensated on Client Cash Account balances. (cid:120) Deposit Cash Account (DCA). LPL's DCA sweep service option automatically sweeps otherwise uninvested cash balances held within certain advisory accounts into interest bearing bank deposits eligible for FDIC Insurance (subject to applicable limits). In the DCA program, each Bank pays compensation equal to a percentage of the average daily aggregated omnibus deposit balance held at the bank. This amount includes the fee for the third-party administrator, LPL’s per account fee, and interest payable to participating accounts. Such fees differ among the participating banks. Customers have no rights to the amounts paid by the DCA participating banks, except for interest actually credited to the customer account. However, amounts collected from the DCA participating banks during each period, less interest credited, will be allocated on a per-dollar, per-account basis and used to offset each customer’s monthly LPL account fee for providing the sweep services. In addition, part of the payment by the participating banks will be used to compensate the third-party administrator for its services. For its services under the DCA program, including making the platform available, LPL receives a per-account fee each month. The monthly fee is based on a fee schedule indexed to A 1 2 – L P L E – 1 0 2 5 P a g e 1 4 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE the current Federal Funds Target (FFT) Rate as detailed in the DCA Disclosure Booklet located on lpl.com. The current fee can also be found at lpl.com. It is expected that this fee will be recouped from the DCA participating banks and will not be a fee directly applied to customer accounts. The fee LPL receives under the DCA program does not vary, and is not affected by the actual amounts held in the deposit accounts or in the customer’s account. LPL has chosen to offer DCA as the sole service option for certain account types, in part because of the additional compensation LPL earns from the use of DCA. In situations where customer cash balances in DCA exceed the deposit availability at DCA participating banks, uninsured cash balances may be placed into an “overflow” money market mutual fund. See below for further information about fees generated by cash balances maintained in the DCA “overflow” money market mutual fund. (cid:120) Client Cash Accounts – ICA Overflow Balances. LPL receives additional compensation and benefits from the customer cash balances maintained in the ICA overflow mechanism, referred to as Client Cash Account, which constitute free credit balances available for LPL use. LPL can use free credit balances to fund its ongoing operations subject to the limitations under SEC Rule 15c3-3. Pursuant to Rule 15c3-3, LPL can (i) deposit free credit cash balances into a segregated deposit account at its banks, thereby earning interest on the Client Cash Account balances deposited, or (ii) invest the cash balances in securities backed by the full faith and credit of the U.S. government, thereby making money on any yield generated by such securities. The amount LPL will earn from these sources will vary based on market forces and the contracts for deposit arrangements that LPL is able to secure with its banks. LPL may use both or either of these vehicles at its sole discretion. Any amounts LPL receives pursuant to these sources will be reduced by the interest payable, if any, to customers on such balances, and further reduced by the cost of borrowing any funds necessary to meet its reserve requirements under Rule 15c3-3. For example, LPL may earn interest or a return by investing in short- term U.S. Government or Agency instruments or by using these balances to fund margin loans to its customers at a lower funding cost than would otherwise be the case. Customers do not share in the returns or proceeds associated with LPL's use or investment of such free credit balances, which are expected to exceed the amount of any Interest paid to the customer for Client Cash Account balances. (cid:120) Money Market Mutual Fund Sweep Option. For customer accounts not eligible for ICA or DCA, otherwise uninvested cash balances held in the account are automatically swept and invested daily into shares of a money market mutual fund. Currently, taxable and tax-exempt money market funds offered by J.P. Morgan Asset Management and Federated Services Company, are available. LPL receives compensation in the form of servicing fees of up to 0.25% of customer assets invested in J.P. Morgan Asset Management money market funds and up to 0.35% of customer assets invested in Federated Services Company money market funds. These money market mutual funds generally pay higher 12b-1 fees than other money market funds that are not used for sweep services. The 12b-1 fees and the payer of such fees are set out in the prospectus of the money market mutual fund. LPL receives service and administrative fees relating to the support of the sweep program from the sponsors of these funds, ranging between 0.25% and 0.45% of the assets Invested In the money market funds. Such fees may be waived by the fund companies in their sole discretion. These payments are in addition to other fees (e.g., recordkeeping and 12b-1 fees) received by LPL, where applicable. LPL also receives fees of up to 0.45% for DCA “overflow” balances that are swept into the Goldman Sachs Asset Management Financial Square Government Fund, if any. The fees and the payer of such fees are set out in the prospectus of the money market fund. The compensation that LPL receives related to ICA, DCA (including from any ICA and DCA overflow mechanisms) and the Sweep Funds is in addition to the Account Fee received with respect to the assets in the sweep investment. This compensation related to ICA, DCA and Sweep Funds is an important revenue stream and presents a conflict of interest to LPL and LPLE because LPL has a financial benefit if cash balances are maintained in the ICA, DCA or Sweep Fund. However, the compensation LPL receives on ICA, and DCA and Sweep Funds is retained by LPL and is not shared with LPLE or its IARs. In addition, LPL Research does not take into account this compensation when it makes decisions on a Portfolio’s allocation to cash. A 1 2 – L P L E – 1 0 2 5 P a g e 1 5 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE Collateralized Lending Arrangements LPL has partnered with certain banks to help facilitate clients’ access to non-purpose lines of credit collateralized by their investment accounts. Because of LPL’s arrangements with the banks participating in the collateralized lending program, clients may be limited in their ability to negotiate the most favorable loan terms. Clients are not required to use the banks in LPL’s collateralized lending program, and can work directly with other banks to negotiate loan terms or obtain other, potentially more favorable, financing arrangements. If a client obtains a loan from a non-partner bank, they should notify their IAR of the amount of the line of credit. Clients should understand that the interest and additional fees paid to the bank in connection with the loan are separate from and in addition to the advisory fees the client pays LPL for its advisory services on the account. LPL receives third-party compensation from participant banks based on the amount of outstanding loans. Compensation can be up to 0.75% of the outstanding loan amount. This compensation to LPL varies, and, therefore, LPL can earn more or less depending on the bank selected by the client. The receipt of compensation poses a conflict of interest to LPL and LPLE because LPL has a financial incentive for the client to select a bank in the collateralized lending program, as well as a participating bank that pays LPL more than other participating banks. However, LPL does not share this compensation with LPLE or its IARs, and therefore, IARs of LPLE do not have a financial incentive if one bank is selected over another. LPL and LPLE have an interest in continuing to receive investment advisory fees, which gives LPLE and its IARs an incentive to recommend that clients borrow money rather than liquidate some of their assets managed by LPLE and its IARs. This incentive creates a conflict of interest for LPLE and its IARs when advising clients seeking to access funds on whether they should liquidate assets or instead hold their securities investments and utilize a line of credit secured by assets in their account. Because LPL and LPLE are compensated primarily through advisory fees paid on clients’ accounts, LPL and LPLE also have an interest in managing an account serving as collateral for a loan in a manner that will preserve sufficient collateral value to support the loan and avoid a bank call. This presents a conflict of interest with clients because it could incentivize LPLE’s IARs to invest in more conservative, lower performing investments to maintain the stability of the account. For additional information regarding LPL’s collateralized lending program, including a list of the banks currently participating in this program, please visit lpl.com/disclosures.html, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Third Party Compensation and Related Conflicts of Interest.” Credit Cards As part of its cash management services, LPL makes available for its customers credit cards through a partner bank. LPL receives a flat fee for each new activated credit card that is used by the cardholder in the first 90 days. LPL also receives a portion of the transaction volume of the cardholder’s account. LPL’s portion of the transaction volume varies depending on the number of LPL active cardholder accounts.(cid:3) Other Clients Client should understand that LPL and LPLE perform advisory and/or brokerage services for various other clients, and that LPL and LPLE may give advice or take actions for those other clients that differ from the advice given to the client. The timing and nature of any action taken for the account may also be different. Review of Accounts IARs of LPLE review accounts and meet with clients, on a regular basis or as requested by the client. IARs have access to review monthly or quarterly accounts statements as well as performance information, and such meetings may include a review of this information with the client. LPL provides clients with regular written reports and statements regarding their accounts. LPL provides detailed performance information annually describing account performance and positions, with additional performance information available upon request. In addition, LPL transmits to clients account statements showing transactions, positions, and deposits and withdrawals of principal and income. Portfolio values and returns shown in performance reports for the year-end time period may include mutual fund dividends paid out prior to December 31 but that were posted to the account within the first 2 business days of the A 1 2 – L P L E – 1 0 2 5 P a g e 1 6 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE subsequent year. The inclusion of such dividends in the year-end performance report may cause discrepancies between the report and the account statement client receives from LPL for the same period. Other Compensation LPL and LPLE employees and their IARs receive additional compensation, business entertainment and gifts from product sponsors. Such compensation may not be tied to the sales of any products or services. Compensation includes such items as gifts valued at less than $100 annually, an occasional dinner or ticket to a sporting event, or reimbursement in connection with educational meetings, customer appreciation events or marketing or advertising initiatives, including services for identifying prospective clients. Product sponsors may also pay for, or reimburse LPL and LPLE for the costs associated with, education or training events that may be attended by LPL and LPLE employees and IARs, and for LPL or LPLE-sponsored conferences and events. LPL and LPLE employees and IARs also receive reimbursement from product sponsors for technology-related costs, such as those to build systems, tools and new features to aid in serving customers. For a current and complete list of the product sponsors that pay such marketing and educational support payments, please see lpl.com/lpl-enterprise.html or ask your IAR. LPL and LPLE employees provide sales support resources to IARs of LPLE that use LPL advisory programs. The compensation that LPL and LPLE pays to these employees varies based on the assets in LPL’s different advisory programs. These employees have an incentive to promote certain advisory programs to IARs of LPLE over other advisory programs. These employees also earn more compensation when IARs transition client assets from brokerage accounts to advisory accounts, and have a financial incentive to encourage IARs of LPLE to transition brokerage accounts to advisory. LPL receives compensation in the form of earnings on its short-term investment of cash in program accounts prior to the time the cash is invested for the account. These earnings are generally known as "float." Cash in the account would typically result from contributions to the account or sales of securities in the account. For accounts that opt out of the sweep program, the accounts may remain in free credit balances. In such case, LPL receives compensation in the form of earnings on cash. LPL does not share this compensation with LPLE or its IARs. In the event a trade error occurs in the Account, and such error is determined to be caused by LPL or LPLE, LPL typically will cancel the trade and remove the resulting monetary loss to the client from the account. If a trade correction is required as a result of client (e.g., if client does not make full payment for purchases or fails to deliver negotiable securities for liquidations before trade settlement), LPL typically will cancel the trade and any resulting monetary loss will be borne by the client. In the case of a trade that requires a correction as described above and that resulted in a monetary gain to the client, such gain will be removed from the account and can result in a financial benefit to LPL. Conflicts Related to Compensation to IARs and Unaffiliated Financial Institutions IARs are associated with unaffiliated financial institutions, like insurance companies. Based on an arrangement between LPLE and the financial institution, IARs offer advisory services. Such advisory services are offered by LPLE and not the financial institution. Any securities recommended as part of the investment advice are not guaranteed by the financial institution, or insured by the Federal Deposit Insurance Corporation or any other federal or state deposit guarantee fund relating to financial institutions. IARs have a financial incentive to negotiate fee arrangements that maximize their compensation. In some programs, LPLE charges a negotiable advisory fee for itself plus a fee for third-party managers that is not negotiable. Differences in fees for third-party managers, and the absence of such fees in other programs, creates a conflict of interest for the IARs insofar as IARs can negotiate a higher LPLE advisory fee for a program or strategy with lower or no separate manager fee than they could for an account subject to a higher third-party manager fee. The amount received by an IAR as a result of a client’s participation in any particular program offered by LPLE often is more than the IAR would have received if the client participated in other programs, paid third-party manager fees, or paid separately for investment advice, brokerage and other services covered by the account fee. LPLE has entered into agreements with the financial institutions pursuant to which LPLE typically shares compensation, including a portion of the Account Fee, with the financial institution or its affiliates. LPLE typically shares between 90% to 100% of the Account Fee with the financial institution with which the IAR is affiliated, or an affiliate of such financial institution, and the A 1 2 – L P L E – 1 0 2 5 P a g e 1 7 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE financial institution or its affiliate pays part of that amount to IAR. The financial institution establishes the compensation plan for the IAR, which is subject to approval by LPLE. The compensation plan determines how the IAR’s compensation is structured. This compensation the IAR receives from the financial institution could be more than if the client participated in other LPLE programs, programs of other investment advisors or paid separately for investment advice, brokerage and other client services, and likewise, the fees that are assessed by LPL or LPLE could be less for OMP than other programs or services. In such cases, the IAR has a financial incentive to recommend advisory services in OMP over other programs and services. Although the IAR may factor in the fees that are assessed by LPL or LPLE in the overall Advisory Fee negotiated by the client, IAR can still earn more for offering OMP at a lower overall fee rate than the fee rate for a program offering a third-party manager. The IAR will have a financial incentive to utilize a particular service or product if under the compensation plan that product will result in more compensation to the IAR than another product or service, including advisory versus brokerage services. If an IAR is recommending an advisory program or service, he or she must believe that the program or service is suitable and in the best interest of the client in accordance with the applicable standards under the Advisers Act or other applicable law. All compensation paid to the financial institution and the IAR will be the sole responsibility of LPLE, and will not result in any increase in the Account Fees you pay to LPL and LPLE. LPLE also may provide other forms of compensation to financial institutions, such as bonuses, awards or other things of value offered by LPL or LPLE to the institution. For example, LPLE pays certain financial institutions based on production, in the form of repayable notes, reimbursement of fees that LPL or LPLE charges for items such as administrative services, and other things of value such as free or reduced-cost marketing materials, transition assistance for changing association from another broker- dealer or investment adviser firm to LPLE, advances of advisory fees, and/or attendance at LPL’s or LPLE’s national conference or top producer forums and events. LPLE pays this compensation based on overall business production and/or on the amount of assets serviced in LPLE advisory programs. LPLE pays this compensation based on overall business production and/or on the amount of assets serviced in LPLE advisory programs. The financial institution and IAR have a financial incentive for an IAR to recommend the program account and services that will result in the greatest compensation to the financial institution and IAR. If LPLE makes a loan to a new or existing financial institution, there is also a conflict of interest because LPLE’s interest in collecting on the loan affects its ability to objectively supervise an IAR at that financial institution. In addition, financial institutions are eligible to receive financial assistance from LPL in connection with transferring existing client accounts serviced at an approved third-party investment program to an on-platform LPL advisory or brokerage account (“Operational Assistance”). These payments are typically calculated as a percentage of assets transferred to LPL up to 0.15%, but in some cases may involve a flat amount up to $350 per transferred account. While Operational Assistance is intended to offset bona fide time and effort incurred by the financial institution’s IARs in identifying and coordinating transfers, these payments can create an incentive for IARs to recommend that clients transfer their assets to on-platform LPL advisory and brokerage accounts since this will result in additional compensation to the financial institution. However, an IAR may only recommend a program or service that he or she believes is suitable and in the best interests of a client in accordance with the standard of care under applicable law. Some of these financial institutions are affiliated with investment product sponsors, meaning that the investment products are sponsored by the financial institution. An IAR associated with a financial institution has a conflict of interest when IAR encourages clients to invest in that financial institution’s proprietary investment products because the financial institution can influence the compensation paid to the IAR or terminate their relationship with the IAR altogether. Certain IARs are statutory agents of financial institutions that are affiliated with investment product sponsors, which means that they receive benefits and insurance as part of their contractual arrangement with those financial institutions. To be statutory agents, such IARs must primarily sell insurance products as their principal business activity, which creates a conflict of interest because such forms of non-cash compensation incentivize IARs to utilize proprietary products. In addition, when an affiliated investment product is selected for an account, the financial institution receives a portion of the Account Fee pursuant to the agreement between LPLE and the financial institution and its affiliate receives fees from the affiliated investment product except to the extent those fees are credited back to the client’s account. Because affiliates of the financial institution earn fees and other benefits from the affiliated product, the IAR has an incentive to select its affiliated products based on the compensation and benefits its affiliates A 1 2 – L P L E – 1 0 2 5 P a g e 1 8 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE receive rather than on a client’s needs. Certain financial institutions provide credits for affiliated investment products. We update this information from time to time on lpl.com/disclosures.html. For more information, click on “Account Disclosures, Agreements, Fee Schedules & Conflicts of Interest,” and then “Third Party Compensation and Related Conflicts of Interest.” Note that the IAR does not receive additional compensation from the financial institution for selecting affiliated products and the IAR may only utilize an investment product that he or she believes is appropriate for clients. LPL reviews and selects investment products for the program and LPL may elect to remove or replace an investment product. There is a conflict of interest because the business relationship between LPL and the financial institution could affect LPL’s ability to objectively select and determine whether to continue to maintain these investment products in the program. However, LPL only approves investment products that it determines are suitable and in the best interests of clients using the program, depending on clients’ investment objective and risk tolerance. Financial Information and Custody LPLE will utilize LPL to maintain custody of assets in the Program. LPL is a qualified custodian as defined in Rule 206(4)-2 under the Advisers Act and maintains custody of OMP client funds and securities in a separate account for each client under the client’s name. LPL as a qualified custodian sends account statements showing all transactions, positions, and all deposits and withdrawals of principal and income. LPL sends account statements periodically when the account has had activity or quarterly if there has been no activity. Clients should carefully review those account statements. Brokerage Practices LPLE requires that clients direct LPL as the sole and exclusive broker-dealer to execute transactions in an OMP account. Clients should understand that not all advisors or program sponsors require their clients to direct brokerage. The fact that LPLE’s affiliate, LPL, is the sole broker-dealer on the account presents a conflict of interest. By directing brokerage to LPL, clients may be unable to achieve the most favorable execution of client transactions. However, clients should understand that LPL is not paid a commission or transaction charge for executing transactions in OMP accounts and execution is made at the net asset value of the mutual fund. Although LPL is not paid a commission or transaction charge for transactions in the account, LPL charges a $5 transaction charge for each transaction (unless waived as described herein). Because LPL bears costs for each transaction made in an account. This presents a conflict of interest because these costs may be a factor LPL considers when deciding which securities to select and whether or not to place transactions in an account. However, LPL mitigates this conflict by compensating the team responsible for directing the trades through a bonus based on the performance of the portfolios; therefore, the team is not incentivized by cost reduction. LPL will aggregate transactions for a client with other clients. LPL also will aggregate rebalancing transactions for an account with other program accounts. Due to the large number of accounts that may be involved in rebalancing transactions on a single day, LPL may effect transactions for some accounts on one day and for other accounts on the following day or days. In such case, LPL will have discretion to sequence the accounts involved in rebalancing transactions with the goal of treating all accounts equitably over time. LPL will reinvest dividends in accordance with LPL’s Dividend Reinvestment Program (“DRP”). Some securities held in the Account may be ineligible for DRP, including securities not custodied at LPL Financial. There is no requirement to participate in the DRP, Client can enroll or unenroll at any time by contacting their IAR or LPL. DRP transactions will be confirmed on at least a quarterly basis as part of the regular periodic account statement. Additional important disclosures about DRP, including eligibility, fees, how dividends are reinvested, and more can be found at lpl.com/disclosures.html. Certain orders may be blocked or subject to review by LPL before they are directed to an exchange or market maker for execution. This review may result in a delay in execution. LPL reserves the right to place restrictions on your account in our sole discretion, and to cancel any order that we believe would violate federal credit regulations or other regulatory limitations; however, LPL will have no responsibility or liability for failing to cancel any order. A 1 2 – L P L E – 1 0 2 5 P a g e 1 9 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  OPTIMUM MARKET PORTFOLIOS – PROGRAM BROCHURE Brochure Supplements Accompanying this Brochure are Brochure Supplements for members of the LPL Research team. Note that although these individuals are responsible for certain investment advice provided by LPL, and may meet with LPLE clients from time to time, they are not responsible for the ongoing individualized provided to a particular client. For more information about the IAR(s) managing your account, please refer to the Brochure Supplement(s) for your IAR(s), which should have been provided along with this Brochure at the time you opened your account. If you did not receive a Brochure Supplement for your IAR(s), please contact your IAR or LPLE at LPLEnterprise.ADV@lpl.com. A 1 2 – L P L E – 1 0 2 5 P a g e 2 0 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS March 31, 2025 1055 LPL Way Fort Mill, SC 29715 (704) 733-3300 www.lpl.com Marc Andrew Zabicki Louis James Carpenetti Garrett Fish Jason Hoody Kristian Kerr Jeffrey Roach Adam Turnquist Lawrence Dean Gillum Jina Yoon Quincy Krosby Thomas Shipp Craig Brown Scott Froidl Jeffrey Alan Buchbinder 201 Washington Street, Suite 300 Boston, MA 02108 (617) 423-3644 George Smith 4707 Executive Drive San Diego, CA 92121 (858) 450-9606 These Brochure Supplements provide information about certain LPL employees or officers that supplements the LPL Financial Brochure that is attached to these Brochure Supplements. Please contact LPL Financial at the number above if you did not receive the LPL Financial Brochure or if you have any questions about the contents of these Brochure Supplements. You may also contact your LPL investment advisor representative with questions. Additional information about these LPL employees or officers is available on the SEC’s website at https://adviserinfo.sec.gov/. Note that although these LPL employees or officers included in these Brochure Supplements are responsible for investment advice provided by LPL they are not the IARs responsible for the ongoing individualized investment advice provided to a particular client. For more information about the IAR managing the account, client should refer to the Brochure Supplement for the IAR, which should have been provided by the IAR along with the LPL Financial Brochure and these Brochure Supplements at the time client opened the account. If client did not receive a Brochure Supplement for the IAR, the client should contact the IAR or LPL at lplfinancial.adv@lplfinancial.com. Marc Andrew Zabicki Educational Background and Business Experience tying a portion of the compensation to Marc Zabicki was born in 1966. He has a BS in Economics from Florida State University and he is a Chartered Financial Analyst (CFA). He is Chief Investment Officer and the Director of Research for LPL Research and has been with the firm since 2020. Prior to joining LPL, he was Chief Investment Officer at Bower Hill Capital Management. Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and the outperformance of all LPL managed portfolios. Disciplinary Information Supervision None. Other Business Activities Mr. Zabicki is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation Mr. Zabicki is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs, and he reports to Rob Pettman, Executive Vice President. The advice provided by Mr. Zabicki is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The Chief Compliance Officer (“CCO”), Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Mr. Zabicki receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 1 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS Louis James Carpenetti Educational Background and Business Experience is a Senior Vice President and Head of Model Portfolio Management at LPL and joined LPL in 2022. Prior to joining LPL, Mr. Fish was a Portfolio Manager at JPMorgan Asset Management. Disciplinary Information None. Other Business Activities Louis James Carpenetti was born in 1971. He has a BS in Management from Palm Beach Atlantic University, an MBA from Georgia College & State University, a CFA Charterholder and has earned the CFP® certification. He is a Senior Vice President of Trading at LPL and joined LPL in July 2021. Prior to joining LPL, Mr. Carpenetti was Managing Director for Truist for 22 years serving in a variety of management and trading capacities. Disciplinary Information Mr. Fish is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. None. Additional Compensation Other Business Activities Mr. Carpenetti is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation tying a portion of the compensation to Mr. Fish receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, the and outperformance of all LPL managed portfolios. Supervision tying a portion of the compensation to Mr. Carpenetti receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, the and outperformance of all LPL managed portfolios. Supervision Mr. Fish reports to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Fish is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Jason Hoody Educational Background and Business Experience As a Senior Vice President, Mr. Carpenetti is responsible for trade execution in LPL’s advisory programs, subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Garrett Fish Educational Background and Business Experience Jason Hoody was born in 1975. He has a BS in Political Science from Clarkson University, an MA in International Affairs from American University, an MS in Finance from Johns Hopkins University, and is a CFA Charterholder. He is a Senior Vice President in Research at LPL and joined LPL in 2015. Prior to joining LPL, he was a Vice President at BB&T and an analyst at KPMG. Garrett Fish was born in 1969. He has a BA in Japanese History from Bates College and is a CFA Charterholder. He B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 2 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS Additional Compensation Disciplinary Information None. Other Business Activities None. Additional Compensation tying a portion of the compensation to Mr. Kerr receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and the outperformance of all LPL managed portfolios. Supervision tying a portion of the compensation to Mr. Hoody receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, the and outperformance of all LPL managed portfolios. Supervision Mr. Kerr reports to Mr. Zabicki, the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Kerr is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Jeffrey Roach Educational Background and Business Experience in 1973. He has a BS Mr. Hoody reports to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Hoody is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Kristian Kerr Educational Background and Business Experience in 1977. He has a BBA Jeffrey Roach was born in Mathematics from Bob Jones University and a MA and PhD in Economics from Clemson University. He is Chief Economist at LPL and joined LPL in 2022. Prior to joining LPL, Dr. Roach was Senior US Economist for Visa Inc, Managing Director, Economist at MacroView Partners and Chief Economist at Horizon Investments. Disciplinary Information None. Other Business Activities Kristian Kerr was born in International Business from Schiller International University in Madrid, Spain. He is a Senior Vice President and the Head of Macro Strategy at LPL and joined LPL in 2023. Prior to joining LPL, Mr. Kerr worked at Citi Private Bank as the Western Region Head of Foreign Exchange & Macro. Disciplinary Information None. Dr. Roach is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Other Business Activities Additional Compensation Mr. Kerr does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Dr. Roach receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 3 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS capping the amount of compensation paid regardless of the return, and tying a portion of the compensation to the outperformance of all LPL managed portfolios. Supervision tying a portion of the compensation to Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and the outperformance of all LPL managed portfolios. Supervision Mr. Turnquist reports up to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Turnquist is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Lawrence Dean Gillum Educational Background and Business Experience Dr. Roach reports to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Dr. Roach is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Adam Turnquist Educational Background and Business Experience Lawrence Gillum was born in 1974. He has a BS from University of Florida and a Master in Business Administration from the University of North Carolina, Keenan Flagler Business School. He is a Vice President of Research at LPL and joined LPL in 2021. Prior to joining LPL, Mr. Gillum served as a Director at Raymond James where he oversaw fixed income research within the firm’s discretionary model platform. Disciplinary Information Adam Turnquist was born in 1984. He has a BS from the University of Minnesota-Duluth and an MBA from the University of St. Thomas. He is Chief Technical Strategist and joined LPL in 2022. Prior to joining LPL, Mr. Turnquist worked as a Vice President, Technical Research Analyst at Piper Sandler. None. Disciplinary Information Other Business Activities None. Other Business Activities Mr. Gillum is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation is a registered representative of LPL. Mr. Turnquist However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation Mr. Gillum receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, Mr. Turnquist receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short- term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 4 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS tying a portion of the compensation to the Supervision and outperformance of all LPL managed portfolios. Supervision Ms. Yoon reports up to Mr. Zabicki, the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Ms. Yoon is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Quincy Krosby Educational Background and Business Experience Mr. Gillum reports up to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Gillum is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Jina Yoon Educational Background and Business Experience Quincy Krosby was born in 1948. She has an MPhil and PhD from The London School of Economics. She is Chief Global Strategist at LPL and joined LPL in 2022. Prior to joining LPL, Ms. Krosby worked at Prudential Financial as Chief Market Strategist. is Chief Alternate Disciplinary Information None. Other Business Activities Jina Yoon was born in 1983. She has a BS and MEng from Investment Cornell University. She Strategist at LPL and joined LPL in 2023. Prior to joining LPL, Ms. Yoon was the Head of Portfolio Management & Senior Portfolio Manager at Nomura Private Capital. Prior to Nomura, she served both Institutional and Private Wealth Clients as the Head of Tactical Strategies at Credit Suisse. Disciplinary Information None. Ms. Krosby is a registered representative of LPL. However, she does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Other Business Activities Additional Compensation Ms. Krosby receives a regular salary. Supervision Ms. Yoon does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation Ms. Krosby reports to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. This is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Ms. Yoon receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short- term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and tying a portion of the compensation to the outperformance of all LPL managed portfolios. B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 5 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS Thomas Shipp Educational Background and Business Experience University and a MAIS in Computational Social Science from George Mason University. He is a Vice President and Head of Quant Strategy at LPL and joined LPL in 2021. Prior to joining LPL, Mr. Brown was a Senior Associate in Investment Analytics and Data at Dimensional Fund Advisors. Disciplinary Information None. Thomas Shipp was born in 1984. He has a BS in Business Administration from Fordham University and is a CFA Charterholder. He is a Vice President and Head of Equity Research at LPL and joined LPL in 2017. Prior to joining LPL, Mr. Shipp was an Associate in the Equity Research Department at BMO Capital Markets. Other Business Activities Disciplinary Information None. Mr. Brown does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Other Business Activities Additional Compensation Mr. Shipp is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation Mr. Brown receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short- term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and tying a portion of the compensation to the outperformance of all LPL managed portfolios. Supervision Mr. Shipp receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short- term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and tying a portion of the compensation to the outperformance of all LPL managed portfolios. Supervision Mr. Brown reports to Mr. Zabicki, the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Brown is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Scott Froidl Educational Background and Business Experience Mr. Shipp reports to Mr. Zabicki, the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Shipp is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Craig Brown Educational Background and Business Experience Scott Froidl was born in 1971. He has a BS from Lindenwood University. He is an Assistant Vice President Senior Investment Analyst at LPL and joined LPL in 2021. Prior to joining LPL, Mr. Froidl was a Senior Investment Analyst at Wells Fargo from 2018 until 2021 and Senior Investment Analyst at Stifel in 2018 while starting with the firm in 2001. Craig Brown was born in 1988 He has a dual BS in Economics and Information Analysis from James Madison B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 6 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS Other Business Activities Disciplinary Information None. Other Business Activities Mr. Buchbinder is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation Mr. Froidl is a registered representative of LPL. However, he does not engage in the sale of securities or receive commissions or other compensation based on the sale of securities or other investment products. Additional Compensation tying a portion of the compensation to Mr. Buchbinder receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short-term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, the and outperformance of all LPL managed portfolios. Supervision Mr. Froidl receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short- term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and tying a portion of the compensation to the outperformance of all LPL managed portfolios. Supervision Mr. Buchbinder reports up to Mr. Zabicki, Chief Investment Officer and the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Buchbinder is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. George Smith Mr. Froidl reports to Mr. Zabicki, the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Froidl is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877-7210. Educational Background and Business Experience Jeffrey Alan Buchbinder in 1983. He has a BS Educational Background and Business Experience in George Smith was born Mathematics from the University of Bristol in the United Kingdom (UK). He is Portfolio Strategist at LPL and joined LPL in 2013. Prior to joining LPL, Mr. Smith worked in London, UK for Legal and General Investment Management (LGIM) and Goldman Sachs Asset Management (GSAM). Disciplinary Information None. Jeffrey Alan Buchbinder was born in 1971. He has a BA in Economics from Northwestern University and an MBA from Duke University. He is Chief Equity Strategist and Portfolio Manager for LPL Financial Research and has been with the firm since 2003. Prior to joining LPL, he served as an Equity Research Associate at Sanford C. Bernstein. Prior to Bernstein, he was an Equity Research Associate at Deutsche Bank. Other Business Activities Disciplinary Information None. Mr. Smith is a registered representative of LPL. However, he does not engage in the sale of securities or receive B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 7 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C  BROCHURE SUPPLEMENTS commissions or other compensation based on the sale of securities or other investment products. Additional Compensation Mr. Smith receives a regular salary and a discretionary bonus. Since the bonus for LPL Research personnel is based on the performance of certain portfolios managed by LPL Research, it presents a conflict of interest because it could incentivize the LPL Research team to focus on short- term performance, take undue risk, or favor certain portfolios over others. LPL mitigates this conflict by basing the bonus calculation on short and long-term performance, capping the amount of compensation paid regardless of the return, and tying a portion of the compensation to the outperformance of all LPL managed portfolios. Supervision Mr. Smith reports up to Mr. Zabicki, the Director of Research of LPL, who is responsible for the advice provided by the LPL Research Department through LPL’s advisory programs. The advice provided by Mr. Smith is subject to LPL’s policies and procedures and to any guidelines established for the applicable advisory program. The CCO, Advisory Compliance is responsible for administering LPL’s policies and procedures for investment advisory activities. The Advisory Compliance Department can be reached at (800) 877- 7210. B r o c h u r e S u p p l e m e n t s – 0 3 2 5 P a g e 8 LL P L F I N A N C I A L L L C M e m b e r F I N R A / S I P C